G.R. No. 182645 ; June 22, 2011
In the Matter of the Heirship (Intestate Estates) of the Late Hermogenes Rodriguez, Antonio Rodriguez, Macario J. Rodriguez, Delfin Rodriguez, and Consuelo M. Rodriguez and Settlement of their Estates, RENE B. PASCUAL, Petitioner, vs. JAIME M. ROBLES, Respondent.

FACTS

On September 14, 1989, Henry F. Rodriguez, Certeza F. Rodriguez, and Rosalina R. Pellosis filed a petition for Declaration of Heirship and Appointment of Administrator (Special Proceeding No. IR-1110) before the RTC of Iriga City. They sought to be declared the sole heirs of the late Antonio Rodriguez and Hermogenes Rodriguez, claiming lineage through Antonio’s son Macario J. Rodriguez, and Macario’s children Delfin and Consuelo. They alleged Hermogenes died without issue, leaving his brother Antonio as his sole heir. The RTC, after no opposition was initially filed, entered a general default and, upon a commissioner’s report, rendered a Partial Judgment on May 31, 1990, declaring Henry, Certeza, and Rosalina as heirs of Antonio and appointing Henry as administrator.
Subsequently, several groups filed oppositions, including respondent Jaime M. Robles, who claimed heirship to Hermogenes and sought appointment as administrator. On December 15, 1994, the RTC issued an Order declaring Robles an heir of Hermogenes, appointing him as regular administrator of Hermogenes’s estate, and authorizing him to sell a property therein. Later, on April 27, 1999, the RTC rendered a decision declaring Carola Favila-Santos and her group as heirs of Hermogenes and reiterating Henry’s group as heirs of Antonio, while dismissing the oppositions of Robles and others. This was amended on August 13, 1999, reversing the finding on Favila-Santos and instead declaring Henry’s group as heirs of both Antonio and Hermogenes, again dismissing Robles’s opposition.
Robles appealed the August 13, 1999 Amended Decision, but his notice of appeal was denied by the RTC on November 22, 1999, for failure to file a record on appeal. Robles then filed a petition for review on certiorari with the Supreme Court, which referred it to the Court of Appeals (CA). On April 16, 2002, the CA rendered a decision annulling the RTC’s August 13, 1999 Amended Decision. Henry Rodriguez’s group moved for reconsideration, which was denied on January 21, 2004; they did not appeal further. Robles also appealed a portion of the CA decision to the Supreme Court, but his petition was denied in a Resolution dated August 1, 2005, which became final and executory on November 10, 2005.
On May 13, 2008, petitioner Rene B. Pascual filed the instant petition for certiorari, assailing the CA’s April 16, 2002 Decision and a subsequent RTC Order dated February 21, 2007, which implemented the CA decision.

ISSUE

Whether the petitioner, Rene B. Pascual, has the legal personality or standing to file the instant petition for certiorari under Rule 65 of the Rules of Court.

RULING

No. The Supreme Court dismissed the petition, holding that petitioner Rene B. Pascual lacks the requisite personality to file the special civil action of certiorari.
The Court ruled that under Section 1, Rule 65 of the Rules of Court, a petition for certiorari may only be filed by a “person aggrieved” by an act of a tribunal exercising judicial functions. This term refers specifically to one who was a party to the original proceedings that gave rise to the action. The Court emphasized that to allow any person who feels injured by a lower court’s order to question it via certiorari would lead to endless litigations, clog court dockets, and harass prevailing parties.
In this case, the original proceedings before the RTC involved the petition for declaration of heirship filed by Henry Rodriguez’s group and the oppositions filed by Jaime Robles and others. The records do not show that Rene B. Pascual was ever a party to those proceedings in Special Proceeding No. IR-1110. Consequently, he is not an “aggrieved party” within the meaning of Rule 65. Having no direct interest or legal standing derived from being a party to the case, he cannot assail the CA Decision or the RTC Order implementing it through a petition for certiorari. The petition was therefore dismissed on this ground.