Case Summary (G.R. No. 200804)
Petition and Underlying Small Claims Case
• On March 23, 2011, petitioner filed a small claims suit under the Small Claims Rules seeking ₱23,111.71 for unpaid water bills covering June 1, 2002 to September 30, 2005.
• Computation: Total consumption of 1,150 cu.m. at P113 per 10 cu.m. plus P11.60 per additional cu.m. yielded ₱28,580.09; respondent had paid only ₱5,468.38.
• Defense: Respondent maintained she paid a flat rate of ₱75 monthly from April 1998 to February 2003; any rate adjustments required prior notice and homeowner approval; she challenged the reasonableness of petitioner’s unilateral rate hikes.
• Petitioner had disconnected respondent’s water line from March 2003 to August 2005 for nonpayment of adjusted charges.
MTCC Decision
• The MTCC held that petitioner’s authority to impose NWRB-approved rates commenced only on August 7, 2003 (date of CPC issuance).
• For June 1, 2002 to August 7, 2003, the agreed flat rate of ₱75 applied, resulting in an obligation of ₱1,050; respondent’s total payments of ₱1,685.99 covered that period.
• It disregarded petitioner’s reliance on an HLURB decision for rate adjustments, finding no proof of required homeowner consultation or HLURB approval.
• For August 8, 2003 to September 30, 2005, the flat rate again applied; respondent owed ₱1,500, had paid ₱300, thus balance ₱1,200 plus 6% interest from October 14, 2010.
• MTCC rendered its decision on June 10, 2011, final and unappealable under Section 23 of the Small Claims Rules.
Petition for Certiorari and RTC Ruling
• Petitioner filed a Rule 65 certiorari petition with RTC to challenge MTCC’s ruling, alleging grave abuse of discretion for disregarding material evidence and misapplying rates.
• On November 23, 2011, RTC dismissed the petition as an improper remedy, noting that small claims decisions are final and unappealable, and a certiorari petition could not supplant the MTCC decision with a larger award.
• A motion for reconsideration was denied on February 16, 2012, prompting recourse to the Supreme Court.
Issue
Did the RTC err in dismissing petitioner’s Rule 65 recourse as improper, notwithstanding the non-appealable nature of small claims decisions?
Supreme Court’s Analysis on Certiorari
• The Small Claims Rules bar appeals (Section 23) but do not preclude certiorari under Rule 65 when no plain, speedy, and adequate remedy exists.
• Jurisprudence (Okada v. Security Pacific; Jaca v. Davao Lumber Co.; Conti v. CA) recognizes certiorari as the proper remedy to correct jurisdictional
Case Syllabus (G.R. No. 200804)
Facts of the Case
- On March 23, 2011, A.L. Ang Network, Inc. (“petitioner”) filed a small claims complaint for sum of money before MTCC-4 of Bacolod City, seeking collection of ₱23,111.71 in unpaid water bills covering June 1, 2002 to September 30, 2005.
- Petitioner, duly authorized to supply and collect water charges in Regent Pearl Subdivision, claimed respondent Emma Mondejar consumed 1,150 cubic meters of water. At P113.00 per 10 cu.m. plus P11.60 per extra cu.m., total charges amounted to ₱28,580.09; respondent paid ₱5,468.38, leaving a balance of ₱23,111.71.
- Respondent countered that she had paid a flat rate of ₱75.00 monthly from April 1998 to February 2003 per their agreement, which could only be adjusted upon prior notice. She challenged the reasonableness and basis of petitioner’s unilateral rate revisions and disputed the ₱23,111.71 claim.
- Petitioner disconnected respondent’s water line from March 2003 to August 2005 for non-payment of adjusted charges.
MTCC Decision
- On June 10, 2011, MTCC-4 held that petitioner’s Certificate of Public Convenience from NWRB was issued only on August 7, 2003, hence petitioner could charge the ₱75.00 flat rate before that date.
- Computation for June 1, 2002 to August 7, 2003: agreed rate of ₱75.00 per month → ₱1,050.00;