Case Digest (G.R. No. 167391)
Facts:
Phil-Ville Development and Housing Corporation is the registered owner of three parcels of land (Lots 1-G-1, 1-G-2 and 1-G-3 of Psd-1-13-006209) in Caloocan City, covered by TCTs Nos. 270921, 270922 and 270923, which it acquired by purchase on July 24, 1984. These parcels form part of Lot 23-A of the Maysilo Estate originally under OCT No. 994 issued May 3, 1917. On September 27, 1961, heirs of Maria de la Concepcion Vidal filed LRC No. 4557 before the CFI of Rizal, resulting in substitution of names on OCT No. 994 by Order dated May 25, 1962. In 1965, a partition petition (C-424) was granted but failed to conclude until 1996 when Judge Discaya ordered partial partition in favor of Eleuteria Rivera, and the Register of Deeds issued TCT C-314537 for Lot 23-14,391.54 sqm. Eleuteria obtained a writ of possession in December 1996, later set aside by the CA in CA-G.R. SP No. 43009 and CA-G.R. SP No. 43034. In June 1997, Phil-Ville filed Civil Case No. C-507 for quieting of title andCase Digest (G.R. No. 167391)
Facts:
- Original titles and subdivisions
- OCT No. 994 was registered on May 3, 1917 in the name of Isabel Gil de Sola as judicial administratrix of the Maysilo Estate (Original Land Registration Case No. 4429).
- Portions of Lot 23-A of the Maysilo Estate were subdivided under subdivision plan Psd-2731 into Lots 1-G, 1-H, etc., covered by TCT No. T-148220.
- Phil-Ville Development and Housing Corporation acquired Lots 1-G-1, 1-G-2 and 1-G-3 (aggregate area: 8,694 m²) by purchase from N. Dela Merced and Sons, Inc. on July 24, 1984, and these are now covered by TCT Nos. 270921, 270922 and 270923.
- Partition proceedings involving OCT No. 994
- In 1961, alleged heirs of Maria de la Concepcion Vidal filed Land Registration Case No. 4557 for substitution on OCT No. 994; the CFI granted substitution on May 25, 1962.
- Petition for partition of OCT Nos. 982–985 and 994 was granted in Civil Case No. C-424; commissioners failed to act.
- On September 9, 1996, the RTC granted a Supplemental Motion to segregate portions of Lots 23, 28-A-1 and 28-A-2, leading to issuance of TCT No. C-314537 in the name of Eleuteria Rivera (portion of Lot 23, area: 14,391.54 m²).
- Writ of possession issued December 26, 1996; notice to vacate served on Phil-Ville and Bonifacio Shopping Center, Inc.
- Court of Appeals (CA-G.R. SP No. 43009 and CA-G.R. SP No. 43034) set aside the 1996 RTC Order, writ and notice to vacate; Eleuteria Rivera died February 22, 1997.
- Department Order No. 137 (April 23, 1997) and Senate Resolution No. 1032 (October 7, 1997) investigated titling anomalies.
- Quieting-of-title action in the RTC
- On June 5, 1997, Phil-Ville filed Civil Case No. C-507 for Quieting of Title and Damages against the surviving heirs of Eleuteria Rivera and the Register of Deeds of Caloocan City.
- RTC, Branch 122, on March 24, 2000 ordered:
- Quieting of TCT Nos. 270921–270923 in favor of Phil-Ville;
- Declaration TCT No. C-314537 (Eleuteria Rivera) is null and void;
- Cancellation of TCT No. C-314537;
- Award of attorney’s fees to Phil-Ville.
- Appeals and CA decisions
- Respondents filed Notices of Appeal, later withdrew their appeal in CA-G.R. CV No. 66547; CA dismissed Danilo Bonifacio and Carmen Bernardino on October 17, 2002.
- Respondents filed a Petition for Review on Certiorari to the Supreme Court (G.R. No. 142640), which was referred to the CA (CA-G.R. SP No. 62211).
- On January 31, 2005, the CA set aside the RTC decision in C-507 and dismissed Phil-Ville’s complaint, ruling the RTC lacked jurisdiction as the action sought annulment of the CFI’s May 25, 1962 Order.
- CA denied Phil-Ville’s motion for reconsideration on March 15, 2005.
- Petition for review on certiorari
- Phil-Ville filed this petition (G.R. No. 167391) to set aside the CA’s January 31, 2005 Decision and March 15, 2005 Resolution.
- Petitioner’s main contentions:
- CA acted without jurisdiction over respondents’ petition;
- RTC had jurisdiction over a quieting-of-title action;
- TCT No. C-314537 is invalid and does not overlap Phil-Ville’s lots.
Issues:
- Jurisdiction of the Court of Appeals
- Whether the CA acted with grave abuse of discretion in taking cognizance of respondents’ Petition for Review in CA-G.R. SP No. 62211 after dismissal of their appeal in CA-G.R. CV No. 66547.
- Jurisdiction of the Regional Trial Court
- Whether the RTC had jurisdiction to hear Civil Case No. C-507 for Quieting of Title and Damages, or whether the complaint was effectively an action for annulment of the CFI Order of May 25, 1962.
- Existence of a cloud on title
- Whether TCT No. C-314537 (Eleuteria Rivera) constitutes a cloud on Phil-Ville’s titles to Lots 1-G-1, 1-G-2, and 1-G-3, given its invalidity and its technical description relative to Phil-Ville’s parcels.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)