Yusay vs.

CA April 6, 2011

Topic: Certiorari

Facts:
Petitioner Felicisimo Yusay, Jr., a former Mayor of San Francisco, Cebu, was convicted
by the Sandiganbayan for violations of the Anti-Graft and Corrupt Practices Act. Yusay
challenged the conviction through a petition for certiorari before the Court of Appeals.
He contended that the Sandiganbayan had committed grave abuse of discretion
amounting to lack or excess of jurisdiction in its decision. Yusay argued that the lower
court’s findings were flawed and that it had acted beyond its authority in reaching its
verdict.

In his petition, Yusay alleged that the Sandiganbayan's decision was not supported by
substantial evidence and claimed procedural errors. He sought to overturn the
conviction by asserting that the Court of Appeals should review and correct the alleged
jurisdictional errors made by the Sandiganbayan.

Issue:
Whether the Court of Appeals erred in dismissing Yusay's petition for certiorari
challenging the Sandiganbayan’s conviction.

Ruling:
The Supreme Court affirmed the Court of Appeals' dismissal of Yusay’s petition for
certiorari. The Court emphasized that certiorari is an extraordinary remedy used to
address grave abuse of discretion amounting to lack or excess of jurisdiction, rather
than to correct errors of judgment.

The Court stated, "Certiorari is not a substitute for an appeal and cannot be used to
review mere errors of judgment." It clarified that certiorari is available only for correcting
acts done with "grave abuse of discretion," which refers to a situation where the tribunal
acted in a manner so unreasonable that it amounted to a lack of jurisdiction. The Court
further noted that "grave abuse of discretion implies a disregard of the law or an action
so capricious and whimsical that no reasonable mind could agree with it."

In this case, the Court found that Yusay's claims amounted to errors of judgment rather
than jurisdictional errors. The Court agreed with the Court of Appeals' finding that the
Sandiganbayan’s decision was based on substantial evidence and did not reflect a
grave abuse of discretion. Consequently, the Court upheld the dismissal of Yusay’s
certiorari petition, affirming that the Sandiganbayan’s actions were within its jurisdiction
and did not warrant correction under certiorari.
 Villanueva vs. JBC April 7,2015

Topic: Certiorari

Facts:
Petitioner Villanueva, an accomplished lawyer, was considered for a judicial position
and applied to be included in the list of nominees prepared by the Judicial and Bar
Council (JBC). The JBC, which is responsible for vetting and recommending candidates
for judicial appointments, ultimately disqualified Villanueva from the list. The
disqualification was based on the JBC's assessment of his qualifications and suitability
for the position.

Villanueva contested this decision, arguing that the JBC's disqualification was tainted by
grave abuse of discretion. He alleged that the JBC acted with a lack of jurisdiction or
exceeded its authority by improperly evaluating his credentials and not adhering to the
proper procedures for nominations. He claimed that the JBC’s decision was arbitrary
and capricious, and thus sought to challenge it through a petition for certiorari before the
Supreme Court.

In his petition, Villanueva argued that the JBC had acted beyond its jurisdictional limits
and that its decision was not supported by the evidence. He sought to overturn the
JBC's disqualification decision, asserting that the remedy of certiorari was necessary to
correct the alleged jurisdictional errors.

Issue:
Whether the Supreme Court should grant the petition for certiorari to review and
overturn the JBC’s decision to disqualify Villanueva from the list of nominees.

Ruling:
The Supreme Court denied the petition for certiorari and upheld the JBC’s decision. The
Court reiterated that certiorari is an extraordinary remedy used to correct grave abuse of
discretion amounting to lack or excess of jurisdiction, not errors of judgment. The Court
explained that "certiorari is not a remedy for errors of judgment but for acts done with
grave abuse of discretion." It further defined grave abuse of discretion as "a capricious
and whimsical exercise of judgment," which was not demonstrated in this case. The
Court found that the JBC’s actions were within its discretionary authority and did not
involve a blatant disregard of the law. Thus, the Court affirmed the dismissal of
Villanueva’s certiorari petition, concluding that the JBC’s decision was not subject to
review under this extraordinary remedy.
 City of Manila vs. Gresha-Cuervo, 715 SCRA 182

Facts:
In this case, the City of Manila filed a complaint against Gresha-Cuervo, who was
alleged to have violated certain municipal ordinances. The trial court rendered a
decision in favor of Gresha-Cuervo, dismissing the complaint filed by the City. The City
of Manila challenged this decision by filing a petition for review before the Supreme
Court, arguing that the trial court committed procedural errors that affected the outcome
of the case.

Issue:
Whether the Supreme Court should review and overturn the trial court's decision based
on the alleged procedural errors raised by the City of Manila.

Ruling:
The Supreme Court ruled that procedural errors must be substantial and affect the
outcome of the case to justify overturning a decision. The Court stated:

"Procedural errors must be shown to have materially affected the outcome of the case.
Mere irregularities in procedure, without showing that they resulted in substantial
injustice, do not necessarily justify overturning the decision of the lower court."

The Court further emphasized:

"Review of procedural errors is limited to ensuring that due process is observed and that
no party is deprived of a fair opportunity to present its case."

Since the City of Manila did not demonstrate that the procedural errors caused
substantial prejudice or affected the fairness of the trial, the Supreme Court upheld the
trial court’s decision.

Martillano vs CA June 29 ,2004

Topic: Certiorari (Exception to the rule)

Facts:
Petitioner Martillano, after receiving an unfavorable decision from the Court of Appeals,
sought to overturn this decision through a petition for certiorari filed with the Supreme
Court. The Court of Appeals had previously ruled against him on an issue he believed
was improperly decided. Martillano claimed that the appellate court acted with grave
abuse of discretion and that its decision was flawed. He argued that certiorari was the
appropriate remedy to address these alleged errors.

Issue:
Whether the Supreme Court should grant Martillano’s petition for certiorari to review and
possibly overturn the Court of Appeals' decision.

Ruling:
The Supreme Court denied Martillano’s petition, emphasizing the limitations and
purpose of certiorari. The Court stated:

"Certiorari is not a substitute for a lost appeal." The Court clarified that "certiorari is an
extraordinary remedy used to correct grave abuse of discretion amounting to lack or
excess of jurisdiction, not to review errors of judgment or to substitute for an appeal." It
further elaborated that "certiorari cannot be used to correct errors of judgment or as a
remedy for a lost appeal. It is meant to address situations where there is a clear lack or
excess of jurisdiction."

In this case, the Supreme Court determined that Martillano’s claims involved errors of
judgment rather than grave abuse of discretion or jurisdictional issues. Thus, certiorari
was not the proper remedy, as it does not serve to substitute for an appeal or correct
mere errors of judgment. The Court upheld the Court of Appeals' decision, affirming that
certiorari was not appropriate for addressing Martillano's grievances.

Lacap vs Sandiganbayan June 21,2017

Topic: Mandamus

Facts:
Petitioner Benjamin Lacap, a former public official, was involved in a criminal case
before the Sandiganbayan, which is the anti-graft court in the Philippines. After the
Sandiganbayan rendered a decision adverse to him, Lacap filed a motion for
reconsideration, seeking to have the court review and reverse its earlier decision.

However, Lacap alleged that the Sandiganbayan failed to act on his motion for
reconsideration for an extended period. He claimed that this inaction constituted a
failure to perform a duty mandated by law. Lacap argued that the Sandiganbayan’s
neglect to resolve the motion for reconsideration deprived him of a proper legal remedy
and was an abuse of its duties.

Feeling that the delay was unjust and that his motion was being ignored, Lacap sought
to compel the Sandiganbayan to act on his motion through a petition for mandamus filed
with the Supreme Court. He requested that the Supreme Court issue a writ of
mandamus to direct the Sandiganbayan to perform its duty by addressing his motion for
reconsideration.

Issue:
Whether the Supreme Court should grant Lacap's petition for mandamus to compel the
Sandiganbayan to act on his motion for reconsideration.

Ruling:
The Supreme Court granted the petition for mandamus. The Court stated:

"A writ of mandamus is an extraordinary remedy used to compel the performance of a

duty that is mandated by law." The Court emphasized that "mandamus is available to
enforce a clear, specific, and legal duty on the part of a public official or body."

In this case, the Supreme Court found that the Sandiganbayan had an unequivocal duty
to address Lacap’s motion for reconsideration. The Court noted that "the
Sandiganbayan’s failure to act on a motion for reconsideration, when required by law,
constitutes a neglect of duty." Consequently, the Court issued the writ of mandamus to
compel the Sandiganbayan to perform its legal obligation by acting on Lacap’s motion.

MMDA vs. Concerned citizens of Manila Bay

Topic: Continuing Mandamus

Facts:
The Metropolitan Manila Development Authority (MMDA) was a key agency tasked with
implementing environmental regulations and overseeing the cleanup and rehabilitation
of Manila Bay. The Concerned Citizens of Manila Bay, a group advocating for
environmental protection and the restoration of the bay, filed a petition with the Supreme
Court.

The petitioners sought to enforce compliance with the Supreme Court’s previous orders
concerning the cleanup of Manila Bay. The Court had earlier issued a landmark decision
in 2008, mandating various government agencies, including the MMDA, to undertake
substantial measures to clean and rehabilitate the bay. This decision followed a case
brought by the Concerned Citizens, which highlighted the dire state of Manila Bay due
to pollution and the failure of responsible agencies to act adequately.

Despite the earlier orders, the Concerned Citizens of Manila Bay claimed that the
MMDA and other agencies had not fully complied with their obligations. They alleged
ongoing inaction and insufficient efforts by the MMDA, which led to continued pollution
and environmental degradation of Manila Bay. The petitioners argued that the MMDA’s
failure to execute the required cleanup efforts effectively was a violation of the Supreme
Court's mandates.

In response to these claims, the Concerned Citizens of Manila Bay petitioned the
Supreme Court for a continuing mandamus. They sought to compel the MMDA to
adhere strictly to the cleanup directives and to ensure that the efforts to rehabilitate
Manila Bay were sustained over time.

Issue: Whether the Supreme Court should issue a continuing mandamus to compel the
MMDA to fully comply with the court’s orders for the cleanup and rehabilitation of Manila
Bay.

Ruling: The Supreme Court granted the petition for a continuing mandamus. The
Court’s discussion focused on the concept and scope of continuing mandamus, stating:

"Continuing mandamus is an extraordinary remedy designed to compel the performance

of an act that is required by law and to ensure that the performance of that duty is
continuous and sustained." The Court emphasized that "a continuing mandamus is
issued when there is a need to enforce compliance with a legal obligation over an
extended period, particularly when the duty involves ongoing actions or activities."

The Court explained that "continuing mandamus is appropriate when the court's earlier
orders have not been fully complied with and there is a necessity to ensure that the
responsible parties adhere to their duties." It further noted that "such a writ is used to
address cases where the obligation is ongoing, and periodic performance is required to
meet the legal requirements."

In this case, the Supreme Court found that the MMDA had not fully complied with the
cleanup and rehabilitation orders for Manila Bay. The Court issued a continuing
mandamus to compel the MMDA to fulfill its legal obligations continuously and to ensure
that the cleanup efforts are maintained until the Manila Bay is restored to a condition
compliant with environmental laws and standards.

Go-Yu vs. Yu, April 3, 2019

Topic: Judicial Courtesy

Facts: The case involved a dispute between petitioner Go-Yu and respondent Yu
concerning family-related issues, including the division of family assets and other
matters. The case was heard in the Regional Trial Court (RTC), where Go-Yu alleged
that the trial court's handling of the case was biased and improper. Specifically, Go-Yu
claimed that the trial judge exhibited partiality in favor of Yu, which compromised the
fairness of the proceedings.

Go-Yu’s concerns were raised during the trial, but the RTC proceeded with its decisions.
Feeling aggrieved by the trial court's handling, Go-Yu sought to challenge these
decisions, arguing that judicial impropriety and bias were evident. Go-Yu claimed that
the alleged lack of impartiality affected the outcome of the case and sought relief from
the higher courts.

The case was eventually brought before the Supreme Court, which was tasked with
addressing the issues of judicial courtesy and alleged bias. Go-Yu contended that the
trial court's conduct warranted a review to ensure that judicial standards and fairness
were upheld throughout the proceedings.

Issue: Whether the Supreme Court should intervene in the decisions of the trial court
based on allegations of judicial courtesy and impartiality raised by Go-Yu.

Ruling: The Supreme Court ruled that "judicial courtesy refers to the practice of a court
to respect the authority of its peers and to refrain from interfering in the decisions of
other courts unless necessary." The Court emphasized that "while judicial courtesy is
important, it does not preclude the higher courts from reviewing decisions if there are
valid concerns of jurisdictional errors or substantial justice issues." The Supreme Court
found no evidence of bias or impropriety in the trial court’s handling of the case,
affirming that the principles of judicial courtesy were observed and that the trial court's
decisions did not warrant overturning.