SAINT MARY CRUSADE TO ALLEVIATE POVERTY OF BRETHREN FOUNDATION,

INC., Petitioner, vs. HON. TEODORO T. RIEL, ACTING PRESIDING JUDGE, REGIONAL
TRIAL COURT, NATIONAL CAPITAL JUDICIAL REGION, BRANCH 85, QUEZON
CITY, Respondent.
G.R. No. 176508, January 12, 2015

FACTS:
The petitioner filed a petition claiming for reconstitution that the original copy of Original
Certificate of Title No. 1609 had been burnt and lost in the fire in the late 80’s that gutted the
Quezon City Register of Deeds. However, respondent Judge Riel of Branch 85 of the Regional
Trial Court (RTC) dismissed the petition for reconstitution through the assailed order, a report
from Land Registration Authority recommending that the petition be dismissed, and considering
the Opposition filed by the Republic of the Philippines and University of the Philippines, petition
is hereby ordered dismissed. Petitioner filed a motion for reconsideration with RTC but it was
denied lack of any cogent or justifiable ground to reconsider. Hence, the petitioner came directly
to the Supreme Court. The Office of the Solicitor General and the University of the Philippines
argued that the petitioner failed to observe the doctrine of hierarchy of courts, despite the Court
of Appeals having concurrent jurisdiction with the Court.

ISSUE:
Whether or not the petitioner violated the observance of the hierarchy of courts.

RULING:
Yes. The Supreme Court ruled that there being no special, important or compelling reason.
The filing of the instant special civil action directly in Supreme 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.