G.R. No. 209551 – 896 Phil. 843 – Political Law – Constitutional Law – The Judicial Department – The Supreme Court – Hierarchy of Courts – The Supreme Court is not a trier of facts
Felino Palafox, Jr. was sued by Sen. Edgardo Angara for damages by reason of defamatory statements allegedly made by Palafox against Angara. Palafox moved for the dismissal of the civil suit on the ground of improper venue (Angara sued Palafox in Pasay City yet both are residents of Makati City). The trial court denied Palafox’s motion to dismiss on the ground that Art. 360 of the Revised Penal Code allows that a separate civil case from the criminal action may be filed in the business address of the complainant.
Palafox moved for reconsideration but it was denied. He directly filed a petition for certiorari case against Judge Francisco Mendiola with the Supreme Court. Palafox alleged that Judge Mendiola gravely abused his discretion in denying his motions.
ISSUE: Whether or not the petition will prosper.
HELD: No. It violated the rule on hierarchy of courts. The Supreme Court is a court of last resort and must remain to be so in order for it to satisfactorily perform its constitutional functions, thereby allowing it to devote its time and attention to matters within its exclusive jurisdiction and preventing the overcrowding of its docket. Palafox cannot bypass the Court of Appeals.
What are the exceptions to the doctrine of hierarchy of courts?
(1) when dictated by the public welfare and the advancement of public policy;
(2) when demanded by the broader interest of justice;
(3) when the challenged orders were patent nullities; or
(4) when analogous exceptional and compelling circumstances called for and justified the immediate and direct handling of the case.
