Title
Cara vs. Court of Appeals
Case
G.R. No. 127625
Decision Date
May 31, 2000
A police officer dismissed for grave misconduct after a traffic altercation and subsequent administrative rulings; Supreme Court upheld dismissal, citing procedural and evidentiary grounds.
police officer
petition for review
certiorari

Case Summary (G.R. No. 127625)

Factual Background

On March 7, 1993, at around 6:30 in the morning, petitioner and his companion, Abraham Rosagaran, visited a bakery store at the intersection of Anonas Street and Kamias Road, Quezon City. Petitioner parked his owner type jeep in front of the bakery. While petitioner was buying bread, he noticed a blue Nissan Bluebird with plate No. PN-113, owned and driven by respondent Teodoro B. Chua, sideswipe the jeep. Despite hitting the jeep, Chua continued driving until petitioner and Rosagaran chased him and signaled him to pull over.

Chua briefly alighted from his car. Rosagaran approached him, and an argument followed. During the exchange, Chua struck Rosagaran on the face with his fist. Petitioner introduced himself as a police officer (Police Officer 1) and invited Chua to the police station. Chua then immediately pummeled petitioner Cara on the face, causing petitioner to fall to the ground. Petitioner then observed that Chua and Rosagaran engaged in a fist fight. Policemen from the Anonas Sub-station arrived and pacified the protagonists.

Initiation and Progress of the Administrative Case

On April 14, 1993, the People’s Law Enforcement Board (PLEB), Quezon City subpoenaed petitioner for a hearing of an administrative case that Chua leveled against him. The PLEB conducted hearings during which both parties presented their respective evidence. On July 19, 1994, the PLEB rendered a decision finding petitioner guilty of grave misconduct and ordering his dismissal from the Philippine National Police effective immediately.

Petitioner appealed to the Regional Appellate Board, National Police Commission. On May 22, 1995, the Board sustained the PLEB’s findings and dismissed petitioner’s appeal. Petitioner’s motion for reconsideration was later denied by resolution dated August 15, 1995.

Attempts at Review Before the Secretary of the Interior and Local Government

On January 18, 1996, petitioner filed with the Secretary of Interior and Local Government Rafael M. Alunan III a petition for review or appeal from the Regional Appellate Board’s August 15, 1995 resolution. The Napolcom denied the petition on February 2, 1996, holding that the decision was not appealable to the Secretary of the Interior and Local Government.

Court of Appeals Proceedings

On April 2, 1996, petitioner filed with the Court of Appeals a petition for certiorari and mandamus. He sought to set aside the Napolcom’s order dismissing him from service and to compel his reinstatement to the Philippine National Police. On May 10, 1996, the Court of Appeals dismissed the petition. Petitioner then appealed to the Supreme Court, docketed as a further review via certiorari.

Issues Raised and the Controlling Character of Relief Sought

The principal issue before the Supreme Court was whether the Court of Appeals erred in dismissing petitioner’s petition for review of the resolutions of the National Police Commission dismissing him from the police service. The Supreme Court emphasized that the grounds raised in petitioner’s petition involved an appreciation of evidence adduced in the administrative case against him.

The Court of Appeals had held, and the Supreme Court affirmed, that certiorari and mandamus as special civil actions are remedies for correcting errors of jurisdiction, not errors of judgment. The Supreme Court also sustained the Court of Appeals’ view that, even assuming the petition could be treated as one for review, it had to be dismissed because it was filed out of time.

The Parties’ Positions Before the Supreme Court

Petitioner’s position required the Court to consider the correctness of the administrative tribunal’s appreciation of the evidence that led to a finding of grave misconduct and his consequent dismissal. In contrast, respondents defended the Court of Appeals’ dismissal by invoking the limits of certiorari and mandamus and by contending that petitioner’s petition was procedurally infirm, particularly for being filed beyond the allowable period.

Ruling of the Supreme Court

The Supreme Court denied the petition for lack of merit, thereby sustaining the Court of Appeals’ dismissal. The Court affirmed both grounds relied upon by the Court of Appeals: (1) the special civil actions of certiorari and mandamus did not lie to correct alleged errors of judgment reached through reevaluation of evidence; and (2) the petition, even if treated as one for review, had been filed out of time.

Legal Basis and Reasoning

The Supreme Court reiterated the doctrinal limitation that certiorari and mandamus are directed at the correction of jurisdictional errors. Where the petitioner’s arguments necessarily required a reexamination of the evidentiary basis of the administrative finding, the proper remedy could not be anchored on those special civil actions.

The Court also upheld the timeliness ruling. In sustaining the Court of Appeals, the Supreme Court relied on jurisprudential statements that petitions for review must comply with prescribed periods, and that petitions filed beyond those periods must be dismissed. The decision cited Purefoods Corp. vs. NLRC, 171 SCRA 415, 426 (1989), with related references to Philippine Rabbit Bus Lines, Inc. vs. Galauran and Pilares Construction Co., 118 SCRA 644 (1982); Fortich vs. Corona, 289 SCRA 624, 642 (1998)

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