Facts:

In the case of Roadway Express, Inc., Danilo C. Flaviano and Jesus I. Guray vs. Court of Appeals, Hon. Judge, Regional Trial Court, Kalookan City, et al., and Edilberto C. Perez, various events unfolded leading to a legal dispute. This case stems from an incident on May 7, 1993, involving a freight truck owned by petitioner Roadway Express and a red Lancer car owned and driven by private respondent Edilberto C. Perez, resulting in an accident. Following the incident, the petitioners filed a complaint for damages against Perez before the Municipal Trial Court (MTC). Perez subsequently filed an answer to the complaint that included a counterclaim. After trial proceedings, the MTC dismissed both the petitioners' complaint, citing a lack of cause of action, and Perez's counterclaim due to it being beyond the jurisdictional limit of the court. The petitioners received the MTC decision on February 27, 1995. They and Perez both appealed the MTC’s decision to the Regional Trial

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Facts:

Background of the Incident

• An accident occurred involving a freight truck registered in the name of Roadway Express, Inc. (petitioner) and a red Lancer car owned and driven by private respondent Edilberto C. Perez.
• The accident resulted in damages, prompting petitioners to file a complaint for damages on May 7, 1993, before the Municipal Trial Court (MTC).

Proceedings in the Lower Courts

• At the MTC:
• Petitioners filed the complaint for damages.
• Private respondent Perez filed his answer along with a counterclaim.
• After trial, the MTC dismissed the complaint for lack of cause of action and likewise dismissed the counterclaim for being beyond its judicial amount.
• Petitioners received a copy of the MTC decision on February 27, 1995.
• At the Regional Trial Court (RTC):
• Both parties appealed the MTC decision to the RTC.
• The RTC affirmed the dismissal of the complaint but “reversed” the dismissal of the counterclaim.
• Petitioners received a copy of the RTC decision on April 25, 1995.

Petition for Review Before the Court of Appeals (CA)

• Petitioners filed a petition for review on May 5, 1995, contesting the lower courts’ rulings.
• On May 26, 1995, petitioners submitted an ex-parte manifestation stating that:
• They had not commenced any similar litigation before the Supreme Court, CA, or any other tribunal or agency with the same issues.
• They undertook to notify the CA should they later learn of any pending action involving the same issues.
• On May 30, 1995, the CA summarily dismissed the petition for review on two grounds:
• The caption did not state the docket number in the trial court.
• There was no certification concerning non-forum shopping.
• Subsequent Developments:
• On June 6, 1995, petitioners filed a motion for reconsideration, citing the inclusion of docket numbers in the records from the lower courts and drawing attention to their prior ex-parte manifestation concerning forum shopping.
• The motion for reconsideration was denied, with the decision received on August 17, 1995.
• Petition for Certiorari:
• Petitioners then elevated the matter by filing a petition for certiorari on August 31, 1995, alleging grave abuse of discretion by both the CA and the lower courts (MTC and RTC).

Allegations of Grave Abuse of Discretion

• Against the CA:
• The alleged error involved the dismissal of the petition for review for non-compliance with Circular 28-91.
• Circular 28-91 mandated additional requirements for petitions filed before the SC or CA, namely:
• The caption must include the docket number of the case in the lower court or quasi-judicial agency.

ii. A certification on the non-forum shopping requirement must be included. ii. The petition for certiorari under Rule 65 was filed beyond the “reasonable period” (more than three months from receipt of the lower court decisions), and such petitions are intended only for correcting jurisdictional errors rather than errors of judgment.

Issue:

Whether the CA committed grave abuse of discretion by dismissing the petition for review based on:

• The absence of the docket number in the caption as required by Circular 28-91.
• The alleged lack of certification concerning non-forum shopping, despite an ex-parte manifestation addressing the issue.

Whether the alleged grave abuse of discretion by the MTC and RTC in dismissing the complaint and counterclaim is meritorious, considering:

• The availability of the remedy of appeal.
• The timeliness of the petition for certiorari under Rule 65.
• The nature of the error – whether it involves jurisdictional error or merely an error of judgment.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)