Case Digest (G.R. No. 224507)
Facts:
On December 8, 2011, Edgardo V. Quesada, Ma. Gracia Quesada‑Manalo, Elizabeth Quesada‑Jose, and Eugenio V. Quesada filed a petition under Section 107, P.D. No. 1529 in the RTC, Quezon City, to compel surrender of the owner’s duplicate of TCT No. 27090 held by Privatization and Management Office (PMO); the duplicate had been delivered in 1983 to secure an obligation under a Growership Agreement and PMO refused to surrender it. The RTC dismissed the petition for lack of jurisdiction; the Court of Appeals set aside the RTC orders, denied PMO’s motion to dismiss, and the PMO filed this petition for review under Rule 45.Issues:
- Did the Court of Appeals err in giving due course to the petition for certiorari instead of treating the remedy as an appeal?
- Did the Regional Trial Court have jurisdiction to entertain the petition to surrender the duplicate title under Section 107, P.D. No. 1529 and to resolve contentious ownership issues?
Ruling:
The petition was denied. The Supreme Case Digest (G.R. No. 224507)
Facts:
- Parties and nature of the petition
- Privatization and Management Office (PMO) is the Petitioner through the Office of the Solicitor General.
- Respondents are Edgardo V. Quesada, Ma. Gracia Quesada-Manalo, Elizabeth Quesada-Jose, Eugenio V. Quesada, represented by their Attorney-in-Fact, Eugenio V. Quesada (the Quesadas).
- The Quesadas filed a Petition to Surrender duplicate Transfer Certificate of Title (TCT) No. 27090 under Section 107 of P.D. No. 1529.
- Origins and title history
- TCT No. 27090 was originally registered in the name of the Quesadas' predecessors-in-interest and was allegedly donated to the Quesadas in 1997 (Deed of Donation).
- The original TCT on file with the Register of Deeds of Quezon City was destroyed in a 1998 fire, prompting a Petition for Reconstitution of Title in Civil Case No. Q-24149 (07).
- The owner's duplicate of the TCT, needed for reconstitution and for registration of the Deed of Donation, was in the possession of PMO.
- How PMO acquired the duplicate TCT
- The owner's duplicate was allegedly delivered in 1983 to Golden Country Farms to secure performance under a Growership Agreement between the Quesadas' predecessor and Golden Country Farms.
- Golden Country Farms later became a sequestered corporation; its assets passed to the Asset Privatization Trust and then to PMO, which retained the duplicate TCT.
- Allegations and antecedent judicial determinations
- The Quesadas alleged whatever obligations existed under the Growership Agreement had been extinguished by prescription.
- In Civil Case No. 8438, RTC Pasay City, Branch 113 issued a Decision dated August 23, 1999 declaring that the Quesadas' predecessors-in-interest had no enforceable liability to Golden Country Farms.
- Pleadings and motions in the RTC (Quezon City, Branch 105)
- PMO, via OSG, filed a Motion to Dismiss alleging: (a) failure to state a cause of action; (b) lack of jurisdiction because the petition involved adverse claims requiring ordinary action; and (c) res judicata as to actions against APT/PMO.
- The Quesadas opposed and insisted there was no annotation or pending registration affecting the title and that PMO did not oppose the Petition for Reconstitution which was decided in their favor.
- On July 3, 2013 the RTC initially denied PMO's Motion to Dismiss to avoid multiplicity of suits and suggested conversion into an ordinary civil action.
- PMO filed a Motion for Reconsideration and a Motion to Suspend Pre-Trial, questioning the RTC's jurisdiction as a land registration court.
- On December 23, 2013 the RTC granted PMO's Motion for Reconsideration and dismissed the petition for lack of jurisdiction.
- The Quesadas filed a Motion for Reconsideration of the December 23, 2013 Order; PMO opposed.
- On April 8, 2014 the RTC denied the Quesadas' Motion for Reconsideration and reaffirmed lack of jurisdiction....(Subscriber-Only)
Issues:
- Procedural propriety of the remedy invoked before the CA
- Whether the CA erred in giving due course to the Petition for Certiorari when certiorari is not the proper remedy to review an order of dismissal that is final and appealable.
- Subject-matter jurisdiction and sufficiency of the petition
- Whether the CA erred in ruling that the RTC, acting as a land registration court, had jurisdiction to take cognizance of the Petition to Surrender the duplicate copy of TCT No. 27090 under Section 107 of P.D. No. 1529.
- Whether the original petitio...(Subscriber-Only)
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)