G.R. No. 155619 - Bayani vs. People

Parties and nature of the case
Respondents Romeo Caballero, Tasiana Caballero, Rufo C. Verano, Paulina C. Verano, Carmen C. Verano, Pascual C. Verano, Eddie C. Verano, Pedro Caballero, Delio Caballero, Victorino Caballero, Lauro Caballero and Cristobal Caballero filed a complaint against petitioners Rosa Baricuatro, Celso Baricuatro, and Anita Baricuatro-Osmena.
The complaint sought quieting of title, cancellation of free patents/OCT, and damages, involving two parcels of land located in Naga, Metro Cebu.
The case required the courts to address issues on which court had jurisdiction over the subject matter and whether petitioners’ claim of forum shopping and res judicata barred a refiling.

First filing in the Regional Trial Court (RTC Branch 16)
On November 15, 1998, respondents filed the complaint with the Regional Trial Court (RTC), Metro Cebu, Branch 16, docketed as Civil Case No. CEB-23101.
On February 23, 1999, RTC Branch 16 issued an Order granting respondents’ motion to withdraw the complaint for re-filing with the proper court.
The Order dated February 23, 1999 explained that the “improper filing” was due to oversight and that the motion to dismiss filed by defendants had become moot and academic.

Re-filing in the Municipal Trial Court (MTC)
On February 26, 1999, respondents re-filed the same complaint with the Municipal Trial Court (MTC) of Naga, Metro Cebu, docketed as Civil Case No. R-414.
The MTC dismissed the case on March 1, 1999 for lack of jurisdiction over the subject matter.
The dismissal Order held that the MTC had no jurisdiction over the subject matter and ordered dismissal.

Motion to reinstate in RTC Branch 16 and its denial
On April 20, 1999, respondents filed before RTC Branch 16 a Motion to Reinstate Case.
RTC Branch 16 denied the motion in an Order dated May 26, 2000.
RTC Branch 16 ruled that the issue of the MTC’s jurisdiction was already resolved by the MTC via its March 1, 1999 Order.
RTC Branch 16 held that the MTC’s March 1, 1999 Order was final because it disposed of the case and that, under Section 1, Rule 40 of the Rules of Civil Procedure, an appeal from a judgment for final order of the MTC could be taken to the RTC with jurisdiction over the area.
RTC Branch 16 denied reinstatement for lack of merit.

Subsequent filing in RTC Branch 13
After the denial by RTC Branch 16, respondents re-filed the complaint with RTC Cebu City, and the case was raffled to Branch 13.
Petitioners filed a Motion to Dismiss in RTC Branch 13 alleging that respondents were guilty of forum shopping.

Proceedings before RTC Branch 13
On December 7, 2000, RTC Branch 13 denied the Motion to Dismiss for lack of factual and legal basis.
On December 26, 2000, petitioners filed their Answer with Affirmative Defense and Counterclaim.
On March 2, 2001, RTC Branch 13 issued an Order setting the case for pre-trial conference.
On March 13, 2001, petitioners filed a Manifestation with Motion to Dismiss, which RTC Branch 13 denied on April 2, 2001 again for lack of factual and legal basis.
Petitioners then sought relief from the Court of Appeals through a Petition for Certiorari, alleging that the RTC had already lost jurisdiction over the subject matter.

Court of Appeals decision and resolution
In a Decision dated September 27, 2002, the Court of Appeals denied the Petition for Certiorari.
The Court of Appeals ruled that an action for quieting of title to real property and cancellation of free patents was within the exclusive original jurisdiction of the RTC.
The Court of Appeals held that the Order of RTC Branch 16 denying reinstatement did not bar Branch 13 from assuming jurisdiction to hear and decide the controversy.
The Cou...(Subscriber-Only)

Whether RTC Branch 16’s Order denying the Motion to Reinstate Case became final and executory such that it caused loss of jurisdiction of the RTC over the case.

Whether respondents should have appealed the denial rather than re-file the complaint.
Whether the RTC lost jurisdiction after the Order became final and executory.
Whether t...(Subscriber-Only)