- Petitioner
- A.L. Ang Network
- Respondent
- Emma Mondejar
- Citation
- G.R. No. 200804
- Court
- Supreme Court
- Division
- Second Division
- Ponente
- Perlas-Bernabe, J.
- Decided
- January 22, 2014
Summary
This Supreme Court case clarified that while decisions in small claims cases are final and unappealable under the Rule of Procedure for Small Claims Cases, this does not preclude the filing of a petition for certiorari under Rule 65 of the Rules of Court. The case involved a water billing dispute where A.L. Ang Network sought to collect P23,111.71 from Emma Mondejar for unpaid water bills. The MTCC awarded only P1,200.00, finding that the petitioner could only charge agreed flat rates before obtaining proper regulatory authorization. When petitioner filed certiorari with the RTC, it was dismissed as an improper remedy. The Supreme Court reversed, holding that certiorari remains available as an extraordinary remedy even in small claims cases where appeal is prohibited, provided there are jurisdictional errors or grave abuse of discretion. The Court emphasized that certiorari petitions against first-level courts should be filed with Regional Trial Courts following the hierarchy of courts doctrine.