As extraordinary
writs, both Sections 1 (certiorari) and 3 (mandamus), Rule 65 of the Rules of
Court require, as a pre-condition for these remedies, that there be no other
plain, speedy and adequate remedy in the ordinary course of law. (Erdito
Quarto vs.
The Hon. Ombudsman Simeon Marcelo, et al, G.R. No. 169042, October 5, 2011, Brion, J.)
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