Case Digest (G.R. No. 189950)
Facts:
The case involves a petition for review on certiorari filed by Bernadette S. Bilag, Erlinda Bilag-Santillan, Dixon Bilag, Reynaldo B. Suello, and the heirs of Lourdes S. Bilag, Leticia Bilag-Hanaoka, and Nellie Bilag (collectively referred to as petitioners) against Estela Ay-Ay, Andres Acop, Jr., Felicitas Ap- Ap, Sergio Ap-Ap, John Napoleon A. Ramirez, Jr., and Ma. Teresa A. Ramirez (collectively referred to as respondents). The events leading to this case began with a Complaint for Quieting of Title with Prayer for Preliminary Injunction filed by the respondents on August 12, 2004, before the Regional Trial Court (RTC) of Baguio City, Branch 61, which was docketed as Civil Case No. 5881-R. The respondents claimed that Iloc Bilag, the petitioners' predecessor-in-interest, had sold them various portions of a 159,496-square meter parcel of land located at Sitio Benin, Baguio City, and that they had registered the corresponding Deeds of Sale with the Register of Deeds of B...
Case Digest (G.R. No. 189950)
Facts:
Background of the Case
The case originated from a Complaint for Quieting of Title with Prayer for Preliminary Injunction filed by respondents (Estela Ay-Ay, Andres Acop, Jr., Felicitas Ap-Ap, Sergio Ap-Ap, John Napoleon A. Ramirez, Jr., and Ma. Teresa A. Ramirez) against petitioners (Bernadette S. Bilag, Erlinda Bilag-Santillan, Dixon Bilag, Reynaldo B. Suello, Heirs of Lourdes S. Bilag, Heirs of Leticia Bilag-Hanaoka, and Heirs of Nellie Bilag) before the Regional Trial Court (RTC) of Baguio City, Branch 61. The dispute involved a 159,496-square meter parcel of land in Sitio Benin, Baguio City, designated as Approved Plan No. 544367, Psu 189147.
Respondents' Claims
Respondents alleged that Iloc Bilag, petitioners' predecessor-in-interest, sold various portions of the land to them through Deeds of Sale, which were registered with the Register of Deeds of Baguio City. They claimed that Iloc Bilag acknowledged full payment and guaranteed that his heirs would honor the sales. Respondents further asserted that they had been in continuous possession of the land since 1976 and had introduced improvements. However, petitioners refused to recognize the sales and allegedly harassed respondents, prompting the filing of the complaint to quiet title and remove the cloud on their ownership.
Petitioners' Defense
Petitioners filed a Motion to Dismiss on three grounds:
- Lack of Jurisdiction: They argued that the land was untitled, unregistered, and part of the Baguio Townsite Reservation, making it public land. Thus, the RTC lacked jurisdiction, and the Land Management Bureau should resolve ownership issues.
- Prescription/Laches/Estoppel: They contended that respondents waited over 27 years to enforce the Deeds of Sale, making the action barred by prescription or laches.
- Res Judicata: Petitioners pointed out that respondents had previously filed a similar case (Civil Case No. 3934-R) in 1998, which was dismissed for lack of merit. The dismissal was affirmed by the Court of Appeals (CA) and became final, barring the current action.
RTC Ruling
The RTC dismissed the case, agreeing with petitioners on all three grounds:
- It lacked jurisdiction over the untitled public land.
- The Deeds of Sale did not confer title, and respondents failed to assert ownership for 27 years.
- The case was barred by res judicata due to the final dismissal of Civil Case No. 3934-R.
CA Ruling
The CA reversed the RTC's dismissal, holding that:
- Res Judicata did not apply because the previous case (Civil Case No. 3934-R) was an action for injunction, while the current case was for quieting of title.
- The action to quiet title was imprescriptible since respondents had been in possession since 1976.
Issue:
The primary issue before the Supreme Court was whether the CA correctly set aside the dismissal of Civil Case No. 5881-R and remanded the case for trial.
Ruling:
The Supreme Court granted the petition and reinstated the RTC's dismissal of the case. It held that:
- The RTC lacked jurisdiction over the case because the subject land was part of the Baguio Townsite Reservation and remained public land. The authority to determine ownership of public lands lies with the Director of Lands, not the RTC.
- The CA erred in not addressing the jurisdictional issue, which was a threshold matter. Any judgment rendered without jurisdiction is null and void.
- The Court did not need to address the other grounds (res judicata and prescription/laches) since the lack of jurisdiction was dispositive.
Ratio:
- (Unlock)