Case Summary (G.R. No. 111854)

Background of the Case

• Petitioners, Barangay Blue Ridge "A" of Quezon City, represented by its officials and individual residents, filed a complaint for injunction and damages against Pilipinas Shell Petroleum Corporation.
• The complaint was filed in the Regional Trial Court of Quezon City on March 2, 1992.
• Pilipinas Shell filed a motion to dismiss the complaint on March 20, 1992, arguing that it failed to state a cause of action.
• The trial court granted the motion to dismiss on January 6, 1993, and denied the petitioners' motion for reconsideration on June 3, 1993.

Court of Appeals Proceedings

• Petitioners alleged grave abuse of discretion by the trial court and filed a petition for certiorari with the Court of Appeals, seeking annulment of the trial court's orders.
• They also requested the inhibition of the trial court judge due to alleged bias and hostility.
• The Court of Appeals denied the petition on July 26, 1993, stating that the proper remedy was an appeal under Rule 41, Section 2 of the Rules of Court, not a special civil action for certiorari under Rule 65.
• A subsequent resolution on September 13, 1993, denied the motion for reconsideration, describing the petition as a "patay na kabayo" (dead horse).

Supreme Court's Review

• Petitioners appealed to the Supreme Court under Rule 45 of the Revised Rules of Court, questioning whether the Court of Appeals erred in denying their petition.
• The Supreme Court found the petition devoid of merit, affirming the Court of Appeals' resolutions.

Legal Principles on Certiorari

• Certiorari is a special civil action that serves as a remedy of last recourse, intended to keep inferior tribunals within their jurisdiction.
• A basic requisite for certiorari is the absence of an appeal or a plain, speedy, and adequate remedy in the ordinary course of law.
• Certiorari cannot be used as a substitute for a lost appeal and is not meant to correct procedural errors or mistakes in a judge's findings.

Abuse of Discretion Defined

• Grave abuse of discretion occurs when a court's power is exercised in an arbitrary manner due to passion, prejudice, or personal hostility.
• Not every error in proceedings or erroneous conclusion of law or fact constitutes abuse of discretion.
• Errors committed by a court in the exercise of its jurisdiction are considered errors of judgment, which should be reviewed through ordinary appeal.

Trial Court's Findings

• The trial court analyzed the elements of a cause of action and d...continue reading

Case Syllabus (G.R. No. 111854)

Background of the Case

• The case involves a complaint filed by the petitioners, represented by the Barangay Blue Ridge "A", against Pilipinas Shell Petroleum Corporation, alleging the construction of a gasoline filling service station violated local barangay ordinances and resolutions.
• The petitioners are not only representing the Barangay but also acting in their capacities as individual residents and homeowners of the area.
• The complaint was filed in the Regional Trial Court of Quezon City on March 2, 1992.

Procedural History

• Following the filing of the complaint, Pilipinas Shell Petroleum Corporation submitted a motion to dismiss on March 20, 1992, arguing that the complaint did not state a cause of action.
• The trial court granted this motion to dismiss on January 6, 1993, and subsequently denied the petitioners' motion for reconsideration on June 3, 1993.
• In response to these decisions, the petitioners filed a petition for certiorari with the Court of Appeals, alleging grave abuse of discretion on the part of the trial court and seeking the judge's inhibition due to perceived bias.

Court of Appeals Decisions

• The Court of Appeals, in its resolution dated July 26, 1993, denied the petition, asserting that an appeal under Rule 41, Section 2 of the Rules of Court was the pro...continue reading