Case Digest (G.R. No. 201821)
Facts:
Pablo B. Malabanan v. Republic of the Philippines, G.R. No. 201821, September 19, 2018, Supreme Court First Division, Bersamin, J., writing for the Court.The Republic of the Philippines, through the Office of the Solicitor General, filed Civil Case No. C-192 in the Regional Trial Court (RTC), Branch 83, Tanauan, Batangas, against Angelo B. Malabanan, Pablo B. Malabanan (petitioner), and Greenthumb Realty and Development Corporation seeking cancellation of titles and the reversion to the public domain of lands said to have been registered ultimately from Original Certificate of Title (OCT) No. 0-17421 (allegedly pursuant to Decree No. 589383, L.R.C. Record No. 50573) and now covered by various Transfer Certificates of Title (TCTs), on the ground that the lands lie within the unclassified public forest and that no decision of the Land Registration Court authorizing the issuance of OCT No. 0-17421 could be found.
The petitioners moved to dismiss in the RTC, arguing that the complaint effectively sought annulment of a Land Registration Court judgment — a remedy cognizable by the Court of Appeals (CA) under Rule 47 — and thus the RTC lacked jurisdiction. The Republic opposed, asserting its action was a reversion and cancellation of title, not an annulment of any judgment, because the alleged Land Registration Court judgment did not exist.
On December 11, 1998, the RTC granted the motion to dismiss Civil Case No. C-192. The Republic filed a notice of appeal, but the defendants moved that the RTC deny due course to the notice of appeal on the ground that the appeal should be by petition for review on certiorari to the Supreme Court as a pure question of law. On June 29, 1999, the RTC denied due course to the appeal and dismissed it. The Republic sought relief in the CA by certiorari (CA-G.R. No. SP No. 54721), and the CA ruled on February 29, 2000 that the RTC had erred in denying due course and should have transmitted the records.
Thereafter the CA addressed the Republic's appealed reversion case on the merits in CA-G.R. CV No. 70770 and, on May 27, 2011, set aside the RTC's December 11, 1998 order and remanded the case for trial, holding that the RTC had jurisdiction over an original action for reversion a...(Pro-only)
Issues:
- Did the Court of Appeals err in setting aside the RTC's December 11, 1998 order dismissing Civil Case No. C-192?
- Should Civil Case No. C-192 be treated as an action to annul the judgment of the Land Registration Court, thereby placing exclusive jurisdiction in the Court of Ap...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)