G.R. No. 217120 - Republic vs. Heirs of Spouses Molinyawe

The Republic of the Philippines filed a petition for review on certiorari seeking the reversal of the Court of Appeals’ February 20, 2015 decision, which dismissed its petition regarding Civil Case No. 10‑658 pending before RTC‑Branch 57, Makati City.
The dispute arose over the cancellation of the lis pendens annotated on the back of Transfer Certificate of Title (TCT) Nos. 75239, 76129, and 77577, and the quieting of title involving these certificates. The cancellation claim was based on prescription, alleging that the Republic failed to execute the final and executory decision of a co‑equal court.

Criminal cases for malversation were filed against Florentino Molinyawe and others in the Court of First Instance (CFI) of La Union.
A forfeiture case was also filed by the Republic via the Office of the Solicitor General (OSG) before the CFI‑Pasig (Civil Case No. 6379) against Florentino, his relatives, and other respondents, alleging that Florentino illegally acquired several parcels of land.

On November 18, 1960, the Republic annotated the forfeiture case on the subject TCTs.
In 1972, the CFI‑Pasig declared the sale of the properties null and void and ordered their forfeiture in favor of the Republic. The decision, affirmed by the Court of Appeals, eventually became final and executory by August 23, 1974, with a writ of execution issued in 1975.
Despite these decisive actions, the Republic failed to cancel the lis pendens and transfer the titles because Florentino did not turn over the owner’s duplicate copies.
On July 9, 2010, the respondents (heirs of Florentino) filed a Complaint/Petition before RTC‑Branch 57 (Civil Case No. 10‑658) seeking cancellation of the annotated lis pendens and quieting of title on the ground of prescription.
Subsequently, on June 10, 2013, the respondents filed a Motion to Admit an Amended and Supplemental Petition to alter or supplement their original pleadings, which was approved by RTC‑Branch 57 in its September 6, 2013 order, despite the existence of a final decision by RTC‑Branch 138 in LRC Case No. M‑5469.
The Republic argued that the trial court (RTC‑Branch 57) acted without jurisdiction and committed grave abuse of discretion by admitting the respondents’ amended petition when the issues had already been finally determined in other proceedings.

RTC‑Branch 57 lacked jurisdiction over the original petition because the main forfeiture action had been decided by the CFI‑Pasig, rendering any collateral effort to cancel the lis pendens improper.
The admission of the Amended and Supplemental Petition effectively attempted to alter the final and executory decision of RTC‑Branch 138.
The Court of Appeals exceeded its jurisdiction under Rule 65 by implying that the civil forfeiture case was contingent or dependent upon the criminal case.

The respondents maintained that RTC‑Branch 57 did have jurisdiction over their petition and that the amendment was proper under the prevailing Rules of Court.

Whether RTC‑Branch 57 had jurisdiction to entertain an action for cancellation of lis pendens and quieting of title when the subject TCTs were already resolved by a forfeiture decision of another court (CFI‑Pasig) that had become final and executory.
Whether RTC‑Branch 57 committed grave abuse of discretion by admitting the respondents’ Amended and Supplemental Petition, thereby attempting to alter findings of a final decision previously rendered by RTC‑Branch 138.
Whether the Court of Appeals improperly extended its analysis under Rule 65 by linking the civil forfeiture case’s resolution to the outcome of an unrelated criminal case.
Whether the acquittal of Florentino in the criminal malversation cases had any bearing on the validity of the forfeiture and subsequent cancellation of the lis pendens.