Case Digest (G.R. No. 208213)
Facts:
The case involves Ayala Land, Inc. as the petitioner and the alleged heirs of Lucas Lactao and Silvestra Aquino, represented by Marcianna Lactao-Garcia, as respondents. The events leading to this case began on September 9, 2005, when the respondents filed a complaint in the Regional Trial Court (RTC) of Quezon City against Ayala Land, Inc. and Capitol Hills Golf and Country Club, Inc. for quieting of title, annulment and cancellation of titles, and reconveyance of possession and ownership concerning a parcel of land known as Lot 42-B-1, Pcs-13, located in Barangay Culiat, Caloocan (now Quezon City), with an area of approximately 215,464 square meters. The respondents claimed that the land had been owned by their grandparents, who died during World War II, and that it was subsequently inherited by their parents. They alleged that Ayala Land and Capitol Hills unlawfully entered their property, bulldozing parts of it and destroying their homes and trees, leading to their displac...
Case Digest (G.R. No. 208213)
Facts:
Background of the Case
- Respondents, the alleged heirs of Lucas Lactao and Silvestra Aquino, filed a Complaint on September 9, 2005, before the Regional Trial Court (RTC) of Quezon City, against Ayala Land, Inc. (petitioner) and Capitol Hills Golf and Country Club, Inc. (Capitol Hills) for quieting of title, annulment and cancellation of titles, and reconveyance of possession and ownership of a parcel of land known as Lot 42-B-1, Pcs-13, located in Barangay Culiat (Balara), Caloocan (now Quezon City), with an approximate area of 215,464 square meters.
Ownership and Possession Claims
- Respondents claimed that the land was owned and possessed by their grandparents, Lucas Lactao and Silvestra Aquino, who died during World War II. Upon their demise, the land was transferred by succession to respondents' parents and predecessors-in-interest, who built houses and planted trees on the property.
Alleged Land-Grabbing
- In 1996, petitioner and Capitol Hills entered into a Joint Development Project over the property south of the subject land. Respondents alleged that petitioner and Capitol Hills forcibly entered their land, bulldozed a portion of it, destroyed their houses and trees, and drove them away through harassment by armed men. Respondents sought a temporary restraining order (TRO) and a writ of preliminary injunction to prevent further land-grabbing.
Payment of Docket Fees
- Respondents paid P6,828.80 in docket fees and executed an Affidavit of Undertaking to settle any deficiency in filing fees through a first lien on any monetary judgment in their favor.
Motion to Dismiss
- Petitioner and Capitol Hills moved to dismiss the Complaint on the grounds of prescription, laches, failure to state a cause of action, and lack of jurisdiction due to insufficient payment of filing fees. They argued that the filing fees should have been based on the fair market value of the property, which they claimed should have been P62,903,240.00.
RTC Proceedings
- The RTC denied the motion to dismiss and granted respondents' application for a TRO. Petitioner moved for reconsideration, arguing that the 1978 Tax Declaration in Lucas Lactao's name did not exist in the Quezon City Assessor's Office.
CA-G.R. SP No. 99631
- Petitioner and Capitol Hills filed a petition for certiorari before the Court of Appeals (CA), docketed as CA-G.R. SP No. 99631, arguing that the RTC never acquired jurisdiction over the case due to insufficient filing fees. The CA denied the petition but ordered the RTC Clerk of Court to reassess the correct amount of docket fees.
G.R. No. 184376
- Both parties filed separate petitions for review before the Supreme Court, which were denied for failure to show reversible error.
Remand to the RTC
- The RTC ordered respondents to pay the reassessed docket fees. Respondents, claiming indigence, filed an Omnibus Motion to have the additional filing fees constitute a lien on the judgment. Petitioner opposed the motion and moved for the dismissal of the case for failure to pay the additional docket fees.
RTC Ruling
- The RTC granted respondents' Omnibus Motion, holding that the additional filing fee could constitute a lien on the judgment, and denied petitioner's motion to dismiss. The RTC also granted respondents' motion to be declared as pauper litigants.
CA-G.R. SP No. 122999
- Petitioner filed a petition for certiorari before the CA, docketed as CA-G.R. SP No. 122999, challenging the RTC's Resolutions. The CA dismissed the petition as moot and academic, holding that the RTC's May 4, 2012 Order granting respondents' motion to litigate as pauper litigants rendered the issue of payment of additional filing fees moot.
Issue:
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Ruling:
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Ratio:
- Mootness: The CA erred in dismissing the petition as moot and academic because the issue of respondents' indigence was still pending resolution. The May 4, 2012 Order could not be considered a supervening event that rendered the issues moot.
- Indigence: The Court held that respondents could still apply for exemption from paying additional docket fees by reason of indigence, even after the finality of the CA's decision in CA-G.R. SP No. 99631. The Court emphasized that access to justice by the impoverished is a constitutional right.
- Payment of Docket Fees: The Court found that respondents sought to be declared as pauper litigants within a reasonable period and that the amount of additional docket fees was still unclear. The Court also noted that the RTC's May 4, 2012 Order granting respondents' motion to litigate as indigent parties was still subject to petitioner's pending motion for reconsideration.
- Remand to RTC: The Court remanded the case to the RTC to resolve the issue of whether respondents qualify as indigent litigants, in accordance with the guidelines set in Algura v. The Local Government Unit of the City of Naga.
Conclusion:
- The Supreme Court set aside the CA's Decision and Resolution but denied petitioner's prayer for the dismissal of the Complaint. The case was remanded to the RTC to resolve the issue of respondents' indigence with dispatch.