G.R. No. 238762 - HEIRS OF SOTERO A. PUNONGBAYAN, REPRESENTED BY CLARITA M. PUNONGBAYAN [DECEASED], SUBSTITUTED BY HER HEIRS, NAMELY: LETICIA M. MAPOY, LUISITO A. MENDOZA, YOLANDA M. DIMAGIBA, AND ELVIRA M. BURAYAG; AND HENIE N. PUNONGBAYAN, VS. ST. PETER'S COLLEGE, INC..DECISION - Supreme Court E-L

Ruling

Accordingly, the documents attached to the Petition satisfy the requirement of the Rules of Court. As to the issue of respondent's alleged lack of authority to file the petition, this Court notes that petitioners have raised this concern in their comment [55] filed before the Court of Appeals. Much like with the proceedings before the Court of Appeals, respondent had already offered its explanation, which petitioners did not refute, thus: Let it be noted that the petition filed at Court of Appeals was initially dismissed but was later on reconsidered after subsequent and substantial compliance made by herein respondent College including submission of Authority of the MANCOM members duly appointed by the corporate court in its Order dated October 30, 2012; Resolution No. 09, s. 2013 dated April 25, 2013, granting authority to the MANCOM to file action and engage the services of legal counsel for the recovery of SPC money. These documents were duly attached in herein respondent's motion for reconsideration at the Court of Appeals and already part of the records of the case. [56] II Under Rule 65, Section 1 of the Rules of Court, the party who may institute a special civil action of certiorari before the Court of Appeals or the Supreme Court is the person considered aggrieved by the assailed order, resolution, or judgment. Tang v. Court of Appeals [57] clarified that the term "person aggrieved" should not be interpreted as any person who feels injured by the lower court's order but "to one who was a party in the proceedings before the lower court[,]" [58] : Although Section 1 of Rule 65 provides that the special civil action of certiorari may be availed of by a "person aggrieved" by the orders or decisions of a tribunal, the term "person aggrieved" is not to be construed to mean that any person who feels injured by the lower court's order or decision can question the said court's disposition via certiorari. To sanction a contrary interpretation would open the floodgates to numerous and endless litigations which would undeniably lead to the clogging of court dockets and, more importantly, the harassment of the party who prevailed in the lower court. In a situation wherein the order or decision being questioned underwent adversarial proceedings before a trial court, the "person aggrieved" referred to under Section 1 of Rule 65 who can avail of the special civil action of certiorari pertains to one who was a party in the proceedings before the lower court. The correctness of this interpretation can be gleaned from the fact that a special civil action for certiorari may be dismissed motu proprio if the party elevating the case failed to file a motion for reconsideration of the questioned order or decision before the lower court. Obviously, only one who was a party in the case before the lower court can file a motion for reconsideration since a stranger to the litigation would not have the legal standing to interfere in the orders or decisions of the sai