G.R. No. 216788 - United Interior Manggahan Homeowners Association vs. De Luna

The petitioner is the United Interior Manggahan Homeowners Association, represented by its President, Daniel Calilung.
The respondents are Spouses Edilberto Villon and Helen Pe-Villon, whose heirs (Emee Pe-Villon, Emmanuel Pe-Villon, Elsie Villon-Cabrera, Elma Villon-Austria, and Ellen Ferrero) represent their interests.

In early 2000, the petitioner filed a complaint before the Regional Trial Court (RTC) for Specific Performance, with a prayer for the issuance of a temporary restraining order, preliminary injunction, and damages against the respondents.
The complaint aimed at enforcing contractual or equitable rights under the premises of homeowner obligations.

After the petitioner presented its case, the respondents filed a Manifestation and Motion to Dismiss on Demurrer to Evidence.
The RTC eventually granted the respondents’ motion in an Order dated March 5, 2014, resulting in the dismissal of the petitioner’s complaint.
The petitioner then moved for reconsideration, which was denied in an Order dated May 6, 2014.

Following the dismissal and denial of reconsideration, the petitioner filed a Notice of Appeal.
The respondents opposed this appeal by filing an Omnibus Motion to Strike Out the Notice of Appeal and Issue a Certificate of Finality.
The respondents contended that the petitioner had failed to attach a board resolution authorizing President Calilung to file the appeal, citing Section 12 of Republic Act No. 9904.
Additional objections raised included non-compliance with the reportorial requirements under Sections 46, Rule 8 and 63, Rule 10 of HLURB Resolution No. 877, Series of 2011, and a failure to show proof of payment of the required appeal fees.

On September 19, 2014, the RTC ordered that the petitioner’s Notice of Appeal be expunged from the case records “for lack of authority from [its] Board of Directors” based on the provisions of RA 9904.
Despite finding that the petitioner had paid the appeal fee within the reglementary period, the RTC maintained its expungement order on the ground of procedural non-compliance.
The petitioner filed a motion for reconsideration, attaching a copy of Board Resolution No. 01, Series of 2013, to substantiate Calilung’s authority.
The RTC, however, denied this motion in an Order dated December 12, 2014, again highlighting failure to present proof of payment for requisite docket and other court fees, and non-compliance with the three-day notice rule under Section 4, 5, and 6, Rule 15 of the Rules of Court.

Unable to effectuate an appeal through ordinary judicial remedies due to the RTC’s orders, the petitioner filed a certiorari petition directly with the Supreme Court.
The central claim is that the RTC committed grave abuse of discretion by expunging the Notice of Appeal based on grounds that are not mandated by law or the applicable procedural Rules.

Whether the RTC gravely abused its discretion in expunging the petitioner’s Notice of Appeal from the case records on the basis of an alleged lack of authority from its Board of Directors.
Whether the supplemental requirements cited by the respondents—such as the submission of a board resolution, compliance with HLURB reportorial rules, and proof of payment of appeal fees—are legally mandated for the filing of a Notice of Appeal.
Whether the trial court actually lost jurisdiction over the case upon the filing of the Notice of Appeal, as argued by the petitioner, or if it retained jurisdiction pending the expiration of the appeal period for other parties.
Whether direct resort to a certiorari petition before the Supreme Court is proper when the challenged orders are final and appellate remedies are ordinarily barred.