The Supreme Court ruled that a petition for certiorari filed directly with the Supreme Court, bypassing the Court of Appeals, was improperly filed. The Court emphasized the importance of observing the hierarchy of courts, clarifying that direct recourse to the Supreme Court is generally not allowed unless there are special and important reasons. This decision reinforces the principle that the Supreme Court is a court of last resort and should not be burdened with cases that can be resolved by lower courts.

Bypassing the Courts: A Case of Procedural Non-Compliance

In this case, petitioners sought to challenge the Department of Justice’s (DOJ) denial of their motions for postponement and remand in certain preliminary investigation cases. Instead of initially filing their petition with the Court of Appeals, they directly approached the Supreme Court via a petition for certiorari. The Supreme Court dismissed the petition on several procedural grounds, including failure to state the material dates of receipt of the assailed DOJ orders and lack of legible copies of these orders. These omissions violated specific rules of court, which the Supreme Court emphasized must be strictly observed in extraordinary remedies such as certiorari.

The Court underscored that certiorari is an extraordinary remedy, and parties seeking this remedy must adhere strictly to the procedural rules. Failure to comply with these rules cannot be dismissed as mere technicality. The decision to accept a petition for certiorari is discretionary on the part of the court. Further, the Supreme Court reiterated the importance of the hierarchy of courts, explaining that while the Supreme Court, Regional Trial Courts, and the Court of Appeals may have concurrent jurisdiction over certain writs, this does not grant unrestricted freedom to choose a court forum.

The principle of hierarchy of courts mandates that recourse should first be sought from the lower courts, such as the Court of Appeals, before elevating the matter to the Supreme Court. This promotes efficiency in the judicial system and prevents overburdening the Supreme Court with cases that could be resolved at a lower level. This approach contrasts with allowing direct access, which would undermine the structure and purpose of a tiered judicial system. The Court emphasized that exceptions to this rule are rare and only apply when dictated by public welfare, advancement of public policy, broader interests of justice, patent nullity of orders, or the inappropriateness of an appeal.

In Talento v. Escalada, the Supreme Court explained:

Although the Supreme Court, Regional Trial Courts, and the Court of Appeals have concurrent jurisdiction to issue writs of certiorari, prohibition, mandamus, quo warranto, habeas corpus and injunction, such concurrence does not give the petitioner unrestricted freedom of choice of court forum. Recourse should have been made first with the Court of Appeals and not directly to this Court.

The Court explicitly stated that the issues raised by the petitioners were within the normal purview of an appeal and did not warrant the use of an extraordinary writ directly before the Supreme Court. The Court of Appeals possesses the jurisdiction to review resolutions issued by the Secretary of Justice via a petition for certiorari under Rule 65, focusing on whether the Secretary of Justice committed grave abuse of discretion. Petitioners failed to take advantage of this readily available avenue, instead of immediately challenging the matter with the Supreme Court.

This decision aligns with the principle that the Supreme Court is a court of last resort. The Supreme Court is tasked with specific functions in the judicial structure of the Philippines. A direct invocation of its original jurisdiction for issuing extraordinary writs should only occur under specific and significant reasons, which must be expressly and precisely outlined in the petition. This policy serves to protect the Court from excessive demands on its time and resources and to prevent overwhelming the Court’s docket.

FAQs

What was the key issue in this case?	The key issue was whether the petitioners properly availed of the remedy of certiorari by directly filing it with the Supreme Court, bypassing the Court of Appeals. The Court reiterated the importance of the hierarchy of courts.
What is a writ of certiorari?	A writ of certiorari is an order from a higher court to a lower court, tribunal, or officer exercising judicial functions to review the records of a case. It’s used when there is an allegation of grave abuse of discretion amounting to lack or excess of jurisdiction.
What does the “hierarchy of courts” mean?	The “hierarchy of courts” is a principle that dictates the order in which courts should be approached for remedies. Generally, lower courts like the Court of Appeals should be utilized before resorting to the Supreme Court.
When can a party directly go to the Supreme Court?	Direct recourse to the Supreme Court is allowed only in exceptional cases. These are dictated by public welfare, the advancement of public policy, broader interests of justice, patent nullities in the order being challenged, or when the appeal is clearly an inappropriate remedy.
What procedural rules did the petitioners violate?	The petitioners failed to state the material dates of receipt of the assailed DOJ orders. They also failed to provide legible copies of the assailed orders, violating Sections 1 and 3 of Rules 46 and 65 of the Rules of Court.
What court should the petitioners have gone to first?	The petitioners should have initially filed their petition for certiorari with the Court of Appeals, which has the jurisdiction to review resolutions issued by the Secretary of Justice.
What is the effect of not following procedural rules?	Failure to strictly observe procedural rules in seeking extraordinary remedies like certiorari can lead to the dismissal of the petition. The Supreme Court does not consider such lapses as mere technicalities.
What was the DOJ’s role in this case?	The Department of Justice (DOJ) issued the Joint Orders that the petitioners sought to challenge. These orders denied the petitioners’ motions for postponement and remand in the preliminary investigation stage.

This case underscores the critical importance of adhering to procedural rules and observing the hierarchy of courts in the Philippine judicial system. The Supreme Court’s decision serves as a reminder that bypassing lower courts is generally not permissible. The principle of hierarchy helps ensure that the Court is able to address cases that truly require its attention as the court of last resort.

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Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: Chong vs. Dela Cruz, G.R. NO. 184948, July 21, 2009