Teodoro Santiago, Jr. vs Juanita Bautista

written by Howard

G.R. No. L-25024 – 143 Phil. 209 – 32 SCRA 188 – Political Law – Constitutional Law – The Judicial Department – Judicial Power – Actual Controversy; Not all disputes may be brought to court

In 1965, Teodoro Santiago, Jr. was ranked 3rd among the graduating elementary pupils of Sero Elementary School in Cotabato City. The ranking was determined by the honor committee of the school. His father questioned the ranking on the ground that there were irregularities in the ranking and that his son should be ranked 2nd. He then filed a certiorari petition with the Court of First Instance of Cotabato alleging that the honor committee gravely abused its discretion and he prayed for the annulment of the ranking. The trial court dismissed his petition. He elevated the matter to the Supreme Court.

ISSUE: Whether or not the controversy brought to court by Teodoro Santiago, Jr. through his father is cognizable by the court.

HELD: No.

Under our Rules, the special action for certiorari must have the following requisites:

  1. that there must be a specific controversy involving rights of persons or property and said controversy is brought before a tribunal, board or officer for hearing and determination of their respective rights and obligations
  2. the tribunal, board or officer before whom the controversy is brought must have the power and authority to pronounce judgment and render a decision on the controversy construing and applying the laws to that end; and
  3. the tribunal, board or officer must pertain to that branch of the sovereign power which belongs to the judiciary, or at least, which does not belong to the legislative or executive department.

In this case, the honor committee is neither a tribunal, a board nor an officer. It did not exercise any judicial or quasi-judicial function.

The SC also emphasized that, in like manner, courts do not have the power to reverse decisions of non-judicial or non-quasi judicial bodies such as decisions of boards of judges in literary or beauty contests or similar competitions.

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