Doctrine of Hierarchy of Courts

Enrico vs. Heirs Of Sps. Eulogio B. Medinaceli

G.R. No. 173614
September 28, 2007
Chico-Nazario, J.

Facts:

The heirs of Spouses Eulogio and Trinidad Medinaceli filed with the RTC, an action for declaration of
nullity of marriage of Eulogio and petitioner Lolita D. Enrico. Impugning that petitioner married without
a valid marriage license. They argued that Article 34 of the Family Code, was not applicable to petitioner
and Eulogio because they could not have lived together under the circumstances required by said
provision.

The RTC issued an Order, dismissing the Complaint for lack of cause of. Respondents filed a Motion for
Reconsideration thereof. Following the filing by petitioner of her Comment to the said motion, the RTC
rendered an Order reversing its previous Order. Aggrieved, petitioner filed a Motion for Reconsideration
of the foregoing Order; however the RTC denied the said motion on the ground that no new matter was
raised therein.

Hence, the instant Petition under Rule 65 of the 1997 Rules of Civil Procedure on the sole question of
whether the case law as embodied in Nial, or the Rule on Declaration of Absolute Nullity of Void
Marriages and Annulment of Voidable Marriages, as specified in A.M. No. 02-11-10-SC of the Supreme
Court applies to the case at bar.

Issue:
Whether or not petitioner violated the doctrine of hierarchy of courts.

Ruling:
Yes, petitioner violated the doctrine of hierarchy of courts.

At the outset, we note that petitioner took an abbreviated route to this Court, countenancing the hierarchy
of courts.

We have earlier emphasized that while the Supreme Court has the concurrent jurisdiction with the Court
of Appeals and the RTCs (for writs enforceable within their respective regions), to issue writs
of mandamus, prohibition or certiorari, the litigants are well advised against taking a direct recourse to
this Court. Instead, they should initially seek the proper relief from the lower courts. As a court of last
resort, this Court should not be burdened with the task of dealing with causes in the first instance. Where
the issuance of an extraordinary writ is concurrently within the competence of the Court of Appeals or the
RTC, litigants must observe the principle of hierarchy of courts. However, it cannot be gainsaid that this
Court has the discretionary power to brush aside procedural lapses if compelling reasons, or the nature
and importance of the issues raised, warrant the immediate exercise of its jurisdiction. Moreover,
notwithstanding the dismissibility of the instant Petition for its failure to observe the doctrine on the
hierarchy of courts, this Court will proceed to entertain the case grounded as it is on a pure question of
law.
 Doctrine of Hierarchy of Courts
People vs. Azarraga
G. R. Nos. 187117
October 12, 2011
Sereno, J.

Facts:

Petitioner filed two (2) Informations before the RTC of against private respondent John Rey Prevendido
for Violation of R.A. No. 9165 or the Comprehensive Dangerous Drugs Act of 2002. The case was re-
raffled twice due to conflict of interest before the other two court judges before Executive Judge Antonio
M. Natino ordered the Clerk of Court to forward the entire records of the cases to Branch 37 presided
over by public respondent, the pairing judge of Branch 36, which was the special court that originally
handled the cases.

However, Prosecutor Amamanglon filed a Motion to Transfer Case to a Branch of Competent

Jurisdiction. Prosecutor Amamanglon also claimed that, as the prosecutor assigned to Branch 37, he was
not among the prosecutors who had been designated to handle cases exclusively involving violations of
R.A. 9165.

On the same day, respondent judge denied the motion. Prosecutor Amamanglon, however, moved for a
reconsideration of respondent judge’s Order, contending that the trial court needed a special designation
from this Court in order to have jurisdiction over the cases but it was once again denied. The city
prosecutor endorsed the assailed Orders of respondent judge to the Office of the Solicitor General for the
appropriate review and filing of the necessary action. Thus, petitioner filed the present petition directly
before this Court.

Issue:
Whether or not petitioner violated the doctrine of hierarchy of courts

Ruling:
Yes, the petitioner violated the doctrine of hierarchy of courts.

At the outset, it is an established policy that parties must observe the hierarchy of courts before they can
seek relief directly from this Court. The rationale for this rule is twofold: (a) it would be an imposition
upon the limited time of this Court; and (b) it would inevitably result in a delay, intended or otherwise, in
the adjudication of cases, which in some instances, had to be remanded or referred to the lower court as
the proper forum under the rules of procedure, or as better equipped to resolve the issues because this
Court is not a trier of facts. It is only for special and compelling reasons that this Court shall exercise its
primary jurisdiction over the extraordinary remedy of writ of prohibition. However, in the case at bar,
since it is only the Supreme Court itself that can clarify the assailed guidelines, petitioner is exempted
from this rule.

The petition, however, must fail.

Contrary to the assertion of petitioner, this Court did not commit any violation of R.A. 9165 when it
issued the assailed guidelines. Rather, it merely obeyed Article VIII, Sec. 5(5) of the 1987 Constitution,
which mandates that the rules promulgated by this Court should provide a simplified and inexpensive
procedure for the speedy disposition of cases.
 Doctrine of Hierarchy of Courts
Saint Mary Crusade, Inc. vs.Hon. Teodoro T. Riel
G.R. No. 176508
January 12, 2015
Bersamin, J.

Facts:

The petitioner claimed in its petition for reconstitution that the original copy of OCT No. 1609 had been
burnt and lost in the fire that gutted the Quezon City Register of Deeds in the late 80’s. Initially,
respondent Judge gave due course to the petition, but after the preliminary hearing, he dismissed the
petition for reconstitution through the first assailed order. The petitioner moved for reconsideration but it
was dismissed for lack of any cogent or justifiable ground to reconsider.
Hence, the petitioner came directly to the Court alleging that respondent Judge had "unfairly abused his
discretion and unlawfully neglected the performance of an act which is specifically enjoined upon him
and5 that "in finally dismissing the herein subject Petition for Reconsideration, respondent Honorable
Acting Presiding Judge has acted without and in excess of his authority and with grave abuse of discretion
to the further damage and prejudice of the herein petitioner;"6 and that it had no other remedy in the
course of law except through the present petition for certiorari and mandamus.

Issue:
Whether or not petitioner can directly come to the Court by petition for certiorari and mandamus.

Ruling:
No, petitioner cannot.

The petition for certiorari and mandamus, being devoid of procedural and substantive merit, is dismissed.
The filing of the instant special civil action directly in this Court is in disregard of the doctrine of
hierarchy of courts. Although the Court has concurrent jurisdiction with the Court of Appeals in issuing
the writ of certiorari, direct resort is allowed only when there are special, extraordinary or compelling
reasons that justify the same. The Court enforces the observance of the hierarchy of courts in order to free
itself from unnecessary, frivolous and impertinent cases and thus afford time for it to deal with the more
fundamental and more essential tasks that the Constitution has assigned to it. There being no special,
important or compelling reason, the petitioner thereby violated the observance of the hierarchy of courts,
warranting the dismissal of the petition for certiorari.

Certiorari, being an extraordinary remedy, is granted only under the conditions defined by the Rules of
Court. The conditions are that: (1) the respondent tribunal, board or officer exercising judicial or quasi
judicial functions has acted without or inexcess of its or his jurisdiction, or with grave abuse of discretion
amounting to lack or excess of jurisdiction; and (2) there is no appeal, or any plain, speedy, and adequate
remedy in the ordinary course of law. The petition for certiorari and mandamus did not show how
respondent Judge could have been guilty of lacking or exceeding his jurisdiction, or could have gravely
abused his discretion amounting to lack or excess of jurisdiction
 Doctrine of Hierarchy of Courts
RAYOS vs. THE CITY OF MANILA
G.R. No. 196063
December 14, 2011
Carpio, J.

Facts:

The present case originated from a complaint for eminent domain filed by respondent City of Manila
against Remedios V. De Caronongan, Patria R. Serrano, Laureano M. Reyes, Paz
B. Sison, Teofila B. Sison, Leticia R. Ventanilla, Rosalinda R. Barrozo (defendants). In its
Complaint, the City of Manila alleged that it passed Ordinance No. 7949 authorizing the City Mayor to
acquire by expropriation, negotiation or by any other legal means the parcel of land co-owned by
defendants. In their Answer, defendants conveyed their willingness to sell the property to the City of
Manila, but at the price of P50,000.00 per square meter which they claimed was the fair market value of
the land at the time.

Petitioners Orlando A. Rayos, Fe A. Rayos Dela Paz, and Engr. Manuel A. Rayos then filed a Motion to
Dismiss on the grounds that Ordinance No. 7949 is unconstitutional. The trial court denied the motion to
dismiss and also denied the motion for reconsideration filed by petitioners.

Hence, this petition.

Issue:
Whether or not petitioner violated the doctrine of hierarchy of courts.

Ruling:
Yes, petitioner did.

Even if the Court treats the present petition as a petition for certiorari under Rule 65, which is the proper
remedy to challenge the order denying the motion to dismiss, the same must be dismissed for violation of
the principle of hierarchy of courts. This well-settled principle dictates that petitioners should file the
petition for certiorari with the Court of Appeals, and not directly with this Court. Indeed, this Court, the
Court of Appeals and the Regional Trial Courts exercise concurrent jurisdiction to issue writs
of certiorari, prohibition, mandamus, quo warranto, habeas corpusand injunction. However, such
concurrence in jurisdiction does not give petitioners unbridled freedom of choice of court forum.

To warrant a direct recourse to this Court, petitioners must show exceptional and compelling
reasons therefor, clearly and specifically set out in the petition. This petitioners failed to do. Petitioners
merely rehashed the arguments in their motion to dismiss, which consist mainly of unsubstantiated
allegations. In the present case, there is absolutely nothing which shows that it has far-reaching
implications and involves transcendental questions deserving of this Courts treatment of the petition as
one for prohibition or mandamus.
 Doctrine of Hierarchy of Courts
Sps. Dy vs. Hon. Bibat- Palamos
G.R. No. 196200
September 11, 2013
Mendoza, J.

Facts:
Respondent filed the Complaint and Petition for Extrajudicial Foreclosure of Preferred Ship Mortgage
under Presidential Decree No. 1521 with Urgent Prayer for Attachment with the RTC for petitioner’s
failure to pay their loan. Following the filing of an affidavit of merit and the posting of bond by
respondent, the RTC ordered the seizure of M/V Pilar-I and turned over its possession to respondent.

The RTC rendered a decision in favor of Spouses Dy, ruling that they had not yet defaulted on their loan
because respondent agreed to a restructured schedule of payment. There being no default, the foreclosure
of the chattel mortgage on M/V Pilar-I was premature. The RTC ordered that the vessel be returned to
Spouses Dy.6 This was affirmed by the CA, with the modification. Petitioner filed a motion for execution
of judgment with the RTC. In his Comment/Objection, petitioner insisted that he had the right to require
that the vessel be returned to him in the same condition that it had been at the time it was wrongfully
seized by respondent or that another vessel of the same tonnage be delivered. Colorado however, stated
that it would be too costly. The RTC issued its questioned Order granting the motion for execution but
denying petitioner’s prayer for the return of M/V Pilar-I in the same state in which it was taken by
respondent.

Petitioner moved for reconsideration but the motion was denied by the RTC. Hence, this petition.

Issue:
Whether or not the rule on hierarchy of courts is applicable to the instant petition?

Ruling:
No, it is not. It falls under one of the exceptions.

Under the principle of hierarchy of courts, direct recourse to this Court is improper because 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. 16 Nonetheless, the invocation of this Court’s
original jurisdiction to issue writs of certiorari has been allowed in certain instances on the ground of
special and important reasons clearly stated in the petition, such as,(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.17

This case falls under one of the exceptions to the principle of hierarchy of courts. Justice demands that
this Court take cognizance of this case to put an end to the controversy and resolve the matter which has
been dragging on for more than twenty (20) years. Moreover, in light of the fact that what is involved is a
final judgment promulgated by this Court, it is but proper for petitioner to call upon its original
jurisdiction and seek final clarification.