A petition for certiorari under Rule 65 filed after the effectivity of A.M. No. 00-2-03-SC benefits from the fresh 60-day period counted from the notice of denial of the motion for reconsideration, even if the original period under the prior rule (Circular No. 39-98) had partially lapsed; furthermore, denying a party the use of written interrogatories based on the outdated notion that it constitutes a "fishing expedition" is a grave abuse of discretion correctible by certiorari, as modes of discovery are liberally granted to enable parties to obtain relevant facts and expedite proceedings.

The case originated from a vehicular accident where a passenger bus owned by petitioner Elena S. Ong and driven by Iluminado J. Caramoan allegedly bumped a jeep owned and driven by respondent Elvira C. Lanuevo, who had respondent Charito A. Tomilloso as a passenger. This incident led respondents Lanuevo and Tomilloso to file a complaint for damages against Ong and Caramoan.

• Respondents Lanuevo and Tomilloso filed a complaint for damages (Civil Case No. 887) against petitioner Ong (bus owner) and her driver Caramoan before the RTC of Guiuan, Eastern Samar, following a vehicular collision.
• After petitioner filed her Answer and respondents filed an Amended Complaint (which was admitted), petitioner served written interrogatories upon the respondents on November 14, 1996.
• Petitioner subsequently filed a "Manifestation and Omnibus Motion" seeking a court order compelling respondents to answer the interrogatories.
• Respondents objected to the motion.
• The RTC, in its Order dated May 6, 1999, denied petitioner's motion, reasoning that the interrogatories constituted a "fishing expedition" and the matters raised would be better addressed during the pre-trial conference.
• Petitioner received the denial order on May 26, 1999, and filed a motion for reconsideration on July 19, 1999.
• The RTC denied the motion for reconsideration in its Order dated July 4, 2000, which petitioner received on July 18, 2000.
• On August 4, 2000, petitioner filed a petition for certiorari under Rule 65 with the Court of Appeals (CA), assailing the RTC's Orders of May 6, 1999, and July 4, 2000, for grave abuse of discretion.
• The CA, in its Resolution dated August 17, 2000, dismissed the petition, finding it was filed two days late based on its computation under Section 4, Rule 65 as amended by Circular No. 39-98 (calculating the remaining period after the motion for reconsideration was denied).
• Petitioner moved for reconsideration, arguing that her petition was a special civil action under Rule 65 with a 60-day reglementary period, not an appeal, and was timely filed.
• The CA denied the motion for reconsideration in its Resolution dated October 10, 2000.
• Petitioner elevated the matter to the Supreme Court via the present petition for review.

• The Court of Appeals erred in dismissing the petition for certiorari for being filed late, as it incorrectly treated the petition as an ordinary appeal subject to a 15-day period or miscalculated the 60-day period under Rule 65.
• The petition for certiorari was timely filed within the 60-day period prescribed by Rule 65, especially considering the retroactive application of A.M. No. 00-2-03-SC which grants a fresh 60-day period from the denial of the motion for reconsideration.
• The Regional Trial Court committed grave abuse of discretion amounting to lack or excess of jurisdiction when it denied the motion to compel respondents to answer the written interrogatories.
• Written interrogatories are a valid and encouraged mode of discovery under the Rules of Court, intended to elicit facts relevant to the case, and should not be disallowed simply as a "fishing expedition."

• The Court of Appeals correctly dismissed the petition, initially suggesting the CA treated it as an appeal because the RTC orders did not warrant certiorari.
• The trial court had jurisdiction to rule on the propriety of the written interrogatories under the Rules of Court (Rule 26, Section 3 cited, though likely meant Rule 25).
• The remedy of certiorari is improper because the denial of the interrogatories, if erroneous, constitutes an error of law or fact, not grave abuse of discretion, and is correctible by appeal in due course.
• The trial court correctly denied the motion to compel answers as the interrogatories constituted a "fishing expedition" and the matters could be properly addressed during pre-trial.

• Whether the Court of Appeals erred in dismissing the petitioner's petition for certiorari on the ground that it was filed out of time.
• Whether the Regional Trial Court committed grave abuse of discretion, correctible by certiorari, in denying the petitioner's motion to compel respondents to answer the written interrogatories.

• Yes, the Court of Appeals erred in dismissing the petition for certiorari as untimely. The Supreme Court applied Section 4, Rule 65, as amended by A.M. No. 00-2-03-SC (effective September 1, 2000) retroactively. This amendment provides that if a motion for reconsideration is filed, the 60-day period for filing the certiorari petition shall be counted from the notice of denial of said motion. Since petitioner received the denial of her MR on July 18, 2000, and filed the petition on August 4, 2000, it was well within the fresh 60-day period provided by the retroactively applied rule.
• Yes, the Regional Trial Court committed grave abuse of discretion in denying the motion to compel answers to the written interrogatories. The trial court's reason that the interrogatories were a "fishing expedition" disregards the purpose and policy of the rules on discovery (Rules 24-29), which encourage parties to discover relevant facts before trial. Leave of court is generally not required for written interrogatories after an answer has been served. The "fishing expedition" objection is no longer a valid reason to prevent discovery.
• While certiorari is generally not available to challenge an interlocutory order (like the denial of interrogatories), an exception exists when the order is patently erroneous and the remedy of appeal would not afford adequate and expeditious relief. The RTC's orders were found to be patently erroneous and not in accordance with law and jurisprudence, justifying the resort to certiorari.
• The Supreme Court set aside the Resolutions of the Court of Appeals and the Orders of the Regional Trial Court, and ordered the Presiding Judge of the RTC to require respondents to serve their answers to petitioner's written interrogatories and proceed with the case dispatch.

• Rule 65, Section 4 (Timeliness of Certiorari): This rule governs the period for filing a special civil action for certiorari. The Court applied the amendment introduced by A.M. No. 00-2-03-SC, which states that the 60-day period is counted from the notice of denial of a timely filed motion for reconsideration, granting a fresh period. This rule was applied retroactively to the petition filed on August 4, 2000, rendering it timely.
• Modes of Discovery (Rules 24-29): These rules provide mechanisms (depositions, interrogatories, requests for admission, etc.) for parties to obtain information regarding any matter, not privileged, which is relevant to the subject of the pending action. The Court emphasized the policy of encouraging availment of discovery modes to allow parties to discover facts before trial, facilitate amicable settlement, or expedite the trial, stating leave of court is generally unnecessary after an answer is served for modes like written interrogatories (Rule 25).
• Written Interrogatories (Rule 25): A mode of discovery where a party serves written questions upon an adverse party, who must answer them under oath. The Court affirmed its utility and held that denying it based on the "fishing expedition" rationale is incorrect, as this objection has been largely discounted by jurisprudence favoring discovery.
• Interlocutory Order: An order issued by the court during the pendency of a case which does not dispose of the case on its merits but resolves preliminary or incidental matters. The Court identified the RTC's orders denying the interrogatories as interlocutory.
• Writ of Certiorari (Rule 65): An extraordinary remedy used to correct errors of jurisdiction or grave abuse of discretion amounting to lack or excess of jurisdiction committed by a tribunal, board, or officer exercising judicial or quasi-judicial functions. The Court held that while generally not available against interlocutory orders, certiorari was proper in this case because the RTC's denial of discovery was patently erroneous and appeal in due course was not an adequate remedy.
• Retroactive Application of Procedural Rules: Procedural laws or rules may be applied to actions pending and undetermined at the time of their passage. The Court applied A.M. No. 00-2-03-SC retroactively as it was a rule of procedure governing the timeliness of filing certiorari petitions.

• "An examination of the petition for certiorari shows that the assailed order dated May 6, 1999 was received on May 26, 1999 and that petitioner filed a motion for reconsideration on July 10, 1999, hence petitioner had only 15 days left from receipt of the order denying the motion for reconsideration on July 18, 2000 or until August 2, 2000 within which to file the petition. When the instant petition was filed on August 4, 2000, the same was late by two (2) days without any explanation being made by petitioner." (Quoted from the CA Resolution, highlighting the error the SC corrected).
• "SEC. 4. When and where petition filed. — The petition shall be filed not later than sixty (60) days from notice of the judgment, order or resolution. In case a motion for reconsideration or new trial is timely filed, whether such motion is required or not, the sixty (60) day period shall be counted from notice of the denial of said motion." (Quoting Sec. 4, Rule 65 as amended by A.M. No. 00-2-03-SC, applied retroactively).
• "Indeed it is the purpose and policy of the law that the parties – before the trial if not indeed even before the pre-trial – should discover or inform themselves of all the facts relevant to the action, not only those known to them individually, but also those known to their adversaries; in other words, the desideratum is that civil trials should not be carried on in the dark; and the Rules of Court make this ideal possible through the deposition-discovery mechanism set forth in Rules 24 to 29." (Quoting Republic v. Sandiganbayan).
• "...the time-honored cry of 'fishing expedition' can no longer provide a reason to prevent a party from inquiring into the facts underlying the opposing party's case through the discovery procedures." (Referencing Republic v. Sandiganbayan).

• Systems Factors Corporation v. NLRC (346 SCRA 149 [2000]) & Unity Fishing Development Corp. v. Court of Appeals (351 SCRA 140 [2001]): Cited as precedents for the retroactive application of A.M. No. 00-2-03-SC, which grants a fresh 60-day period for filing certiorari from the denial of a motion for reconsideration.
• San Luis v. Court of Appeals (365 SCRA 279 [2001]): Cited as justification for the Supreme Court resolving the substantive issue regarding the interrogatories directly, instead of remanding the case to the Court of Appeals, given the similarity of facts and the interest of justice.
• Miranda v. Court of Appeals (71 SCRA 295 [1976]): Cited to support the classification of the RTC orders denying the interrogatories as interlocutory in nature (leaving something more to be done on the merits).
• Salcedo-Ortañez v. Court of Appeals (235 SCRA 111 [1994]): Referenced for the general rule that certiorari is not the proper remedy to challenge an interlocutory order; the remedy is an ordinary appeal from the final judgment incorporating the grounds for assailing the interlocutory order.
• Casil v. Court of Appeals (285 SCRA 264 [1998]) & Go v. Court of Appeals (297 SCRA 574 [1998]): Cited to support the exception to the general rule: certiorari may be allowed against an interlocutory order if it is patently erroneous and appeal would not afford adequate and expeditious relief.
• Republic v. Sandiganbayan (204 SCRA 212 [1991]): Extensively cited to emphasize the policy of encouraging discovery, the purpose of the discovery mechanism (to prevent trials from being carried on in the dark), and to explicitly reject the "fishing expedition" argument as a valid reason to deny discovery.
• Koh v. Intermediate Appellate Court (144 SCRA 259 [1986]): Cited for the rationale behind discovery modes: enabling a party to discover the adverse party's evidence to facilitate amicable settlement or expedite trial.

• Rules of Court, Rule 65, Section 4 (Special Civil Action for Certiorari): Specifically discussed its amendment history (Circular No. 39-98 and A.M. No. 00-2-03-SC) regarding the computation of the 60-day filing period, particularly the effect of filing a motion for reconsideration.
• Rules of Court, Rules 24 to 29 (Modes of Discovery): Generally invoked to underscore the policy encouraging the use of discovery procedures.
• Rules of Court, Rule 25, Section 1 (Written Interrogatories to Parties): The specific discovery mode availed of by the petitioner, which the Court ruled was improperly denied by the RTC.
• Rules of Court, Rule 24, Section 1 (Depositions Pending Action): Mentioned alongside Rules 25 and 26 to illustrate that leave of court is generally not required after an answer has been served.
• Rules of Court, Rule 26, Section 1 (Request for Admission): Mentioned alongside Rules 24 and 25 for the same point regarding leave of court.
• Rules of Court, Rule 26, Section 3 (Effect of failure to file and serve request for admission): Mentioned in the summary of respondent's arguments, although Rule 25 concerning interrogatories was the primary focus.