Case Digest (G.R. No. 185082)
Facts:
The case revolves around Mandaue Realty and Resources Corporation (MARRECO) and the Bangko Sentral ng Pilipinas (BSP), concerning a contested property title. On October 18, 2006, the BSP initiated a Complaint for Annulment of Title/Reconveyance/Reinstatement of Title against MARRECO, leading to Civil Case No. MAN-5524 at the Regional Trial Court (RTC) in Mandaue City, Branch 56. In its Complaint, BSP sought the cancellation of Transfer Certificate of Title (TCT) No. 54456 – registered to MARRECO – and the reinstatement of TCT No. 46781, which BSP claimed covered the same property. BSP supported its claim by asserting the previous RTC Order dated January 19, 2004, from a different case, Gotesco Properties, Inc. v. Bangko Sentral ng Pilipinas, nullified BSP's title to the property and wrongfully restored that title to MARRECO.
Initially, MARRECO responded not by answering the complaint but by filing a Motion to Dismiss on January 29, 2007, raising arguments that included the
...Case Digest (G.R. No. 185082)
Facts:
- Background and Initiation of Litigation
- On October 18, 2006, Bangko Sentral ng Pilipinas (BSP) filed a Complaint for Annulment of Title/Reconveyance/Reinstatement of Title against Mandaue Realty & Resources Corporation (MARRECO) before RTC Branch 56 of Mandaue City.
- The subject of the dispute involved Transfer Certificates of Title (TCT) No. 54456 (registered in MARRECO’s name) and TCT No. 46781 (registered in BSP’s name), covering a property of 40,257 sq.m. in Barangays Poblacion and Subangdaku, Mandaue, Cebu.
- BSP sought cancellation of MARRECO’s title (TCT No. 54456) and reinstatement of its own title (TCT No. 46781), contending that a prior RTC order nullified its title to the property.
- Prior Judicial Determinations and Related Proceedings
- An Order dated January 19, 2004 in Civil Case No. MAN-3902 (Gotesco Properties, Inc. v. Bangko Sentral ng Pilipinas, et al.) was cited, which annulled BSP’s title and restored it to MARRECO by nullifying various documents including:
- The Deed of Absolute Sale and other related instruments executed among the parties.
- The subsequent cancellation and reinstatement of certain TCTs, with the RTC’s order also directing the payment of attorney’s fees by Gotesco Properties, Inc. to MARRECO.
- BSP argued that the January 19, 2004 Order was null and void, thereby justifying its remedial relief in the present complaint.
- Pleadings, Motions, and Procedural Posture
- Instead of answering BSP’s Complaint, MARRECO filed a Motion to Dismiss on January 29, 2007.
- MARRECO’s grounds for dismissal included:
- Lack of jurisdiction of RTC Branch 56 because the complaint purportedly sought to annul a final judgment of a co-equal court.
- BSP opposed the Motion to Dismiss, contending that:
- The complaint was an action for annulment of title under Article 476 of the Civil Code, which falls under the exclusive jurisdiction of the RTC.
- The CA’s resolution in a prior case (CA-G.R. CV No. 81888) was inapplicable.
- BSP was not guilty of forum shopping.
- MARRECO, in its Reply, highlighted BSP’s failure to refute the finality of the January 19, 2004 Order and the subsequent RTC and CA determinations, while reiterating its jurisdictional and legal objections.
- On March 22, 2007, RTC Branch 56 issued an Order dismissing BSP’s complaint on the ground of lack of jurisdiction, ruling that assuming jurisdiction would encroach upon a co-equal court’s domain.
- BSP subsequently appealed the RTC’s dismissal by filing a Notice of Appeal together with its Appellant’s Brief.
- In response, on November 11, 2008, MARRECO filed a Motion to Dismiss Appeal:
- Arguing that the issues raised by BSP were pure questions of law, which must be elevated by petition for review on certiorari under Rule 45 rather than an appeal under Rule 41.
- Contending that BSP’s appeal was frivolous and dilatory.
- Despite being notified by the Court of Appeals (CA), BSP did not file a Comment on MARRECO’s Motion.
- The CA initially denied the Motion to Dismiss Appeal on July 25, 2008, holding that the issues raised involved mixed questions of fact and law, and later, after a Motion for Reconsideration by MARRECO, denied it again on October 21, 2008.
- Relief Sought and Core Argument by the Petitioner (MARRECO)
- MARRECO sought:
- A writ of mandamus directing the CA to dismiss BSP’s appeal.
- A writ of certiorari annulling the CA Resolutions dated July 25, 2008 and October 21, 2008.
- The petitioner contended that since BSP’s appeal raised issues that were purely legal, the CA lacked jurisdiction, as those issues should have been brought via a petition for review on certiorari under Rule 45.
Issues:
- Whether the Court of Appeals committed grave abuse of discretion amounting to excess or lack of jurisdiction when it denied MARRECO’s Motion to Dismiss Appeal and assumed jurisdiction over BSP’s appeal.
- Whether BSP’s appeal involves pure questions of law—which would necessitate a petition for review on certiorari under Rule 45—or mixed questions of fact and law, thereby validating its proper filing under Rule 41.
- Whether the dismissal by RTC Branch 56, premised on jurisdictional non-interference with a co-equal court’s decision, was correctly applied considering the factual matrix surrounding the cancellation of BSP’s title.
- Whether the factual disputes regarding the antecedent events leading to the cancellation of TCT No. 46781 require evaluation by the CA, and consequently, whether the CA properly assumed jurisdiction over such mixed issues.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)