G.R. No. 205573 - Cuan vs. Court of Appeals

Case Summary (G.R. No. 205573)

Case Background

This petition for certiorari and prohibition under Rule 65 of the Rules of Court arises from unresolved disputes surrounding the property initially awarded to Alejandro Lorenzo, Cunanan's father. On January 27, 2009, Mercado filed with the Department of Agrarian Reform (DAR) a petition for the deallocation of a home lot originally granted to Lorenzo. Initially, on April 8, 2010, the DAR dismissed Mercado's petition for lack of merit. However, after a motion for reconsideration submitted by Mercado, the DAR reversed its earlier decision on October 13, 2010, asserting that Lorenzo and his heirs were absentee landlords, consequently recommending the cancellation of the title originally granted to Cunanan.

Procedural History

Cunanan was unaware of the subsequent DAR proceedings until April 2011, when she discovered the final order canceling her title. Following this, Cunanan filed a motion to quash the order of finality, claiming she was not notified throughout the process and thus, the DAR lacked jurisdiction over her person. Concurrently, on June 13, 2011, Cunanan also filed a petition for relief from judgment in which she further argued that the proceedings were null and void due to her exclusion from the process.

Subsequent Filings

Cunanan’s legal efforts continued with a subsequent petition for injunction and prohibition, asserting the urgency of preserving her property rights. However, her petitions were dismissed on various procedural grounds, including failure to comply with court rules and for being moot and academic. Ultimately, the Court of Appeals (CA) dismissed her petitions as it was determined that a petition for review and not certiorari was the appropriate legal remedy. The CA noted that the timelines for filing were not adhered to by Cunanan.

Legal Issues Raised

The core issue presented in the appeal revolved around whether the CA erred gravely in dismissing Cunanan’s petitions without addressing the substantial issue of due process violation. Cunanan argued that the CA's resolutions were null and void because she was not given adequate notice of the proceedings, constituting a grave abuse of discretion.

Counterarguments by Respondents

The Office of the Solicitor General (OSG), representing the respondents, contended that Cunanan’s remedies were mutually exclusive. They argued that certiorari was not an appropriate legal course of action since her claims could have been adequately addressed through an appeal. They further asserted that Cunanan failed to demonstrate the requisite grave abuse of discretion by the CA.

Court's Ruling

The Supreme Court recognized the nature of a petition for certiorari as a corrective measure meant to address jurisdictional errors or grave abuse of discretion. It established that wh