Title
Arroyo vs. Mencias
Case
G.R. No. L-21186
Decision Date
Aug 31, 1965
Lessee Zosimo Arroyo challenged a trial court order requiring rental deposits to the Clerk of Court, bypassing reconsideration. The Supreme Court denied his petition, citing procedural error.

Case Summary (G.R. No. L-21186)

Procedural Background

On March 20, 1961, Ernesto and Ramona Santos initiated an action (Civil Case No. 6557) seeking to settle disputes among the co-owners regarding property management. The trial court's order on January 9, 1963, directed several lessees, including Zosimo Arroyo, to deposit property rentals with the court. The defendants challenged this order, which led to Arroyo's petition for certiorari filed on April 18, 1963, arguing lack of jurisdiction and practicality issues concerning the deposit of rentals.

Legal Issues and Arguments

The primary argument from Zosimo Arroyo’s petition is centered around the claim that he is not a party to the original partition action, thereby questioning the jurisdiction of the trial court over him. He contested the deposit requirement, asserting that transporting the mandated amount of palay from Candaba, Pampanga to the Clerk of Court’s office in Pasig, Rizal would be impractical.

Court's Ruling on Jurisdiction

The court ruled that the petition for certiorari was improperly filed, emphasizing that certiorari is an extraordinary remedy available only when no other adequate relief exists. Since Arroyo had not presented his case to the trial court before seeking relief in the higher court, this failure was deemed fatal to his petition. The court reiterated that it should be given the first opportunity to address potential errors in its rulings before such matters are escalated.

Intervention and Motions

The court noted that while other parties in the original case, namely the defendants, had filed a motion for reconsideration of the January 9 order which was denied, this did not replace Arroyo's obligation to file his own motion. The decision high

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