Case Summary (G.R. No. 189950)
Key Dates and Applicable Law
Applicable constitutional framework: 1987 Philippine Constitution (decision date post‑1990). Statutory and regulatory sources invoked in the decision: Presidential Decree No. 1271 (PD 1271), Commonwealth Act No. 141 (Public Land Act). Relevant jurisprudence cited in the decision is also applied.
Facts
Respondents alleged that Iloc Bilag, predecessor‑in‑interest to petitioners, sold separate portions of the subject lands to respondents and executed corresponding Deeds of Sale, which were registered with the Register of Deeds of Baguio City. Respondents claimed delivery and continuous possession since 1976, introduction of improvements thereon, and that Iloc Bilag had caused the lands to be removed from Ancestral Land Claims. Petitioners refused to recognize those sales, asserted adverse rights, and allegedly threatened respondents’ possession and improvements. Respondents filed a Complaint for Quieting of Title with Prayer for Preliminary Injunction (Civil Case No. 5881‑R).
Procedural Posture — Motion to Dismiss
Petitioners moved to dismiss on three grounds: (1) lack of jurisdiction, alleging the subject lands are untitled public domain within the Baguio Townsite Reservation and that the Land Management Bureau/Director of Lands has exclusive authority to determine ownership; (2) prescription, laches, and estoppel based on respondents’ alleged delay (more than 27 years) in asserting their claims; and (3) res judicata, citing an earlier suit filed by respondents (Civil Case No. 3934‑R before RTC Branch 5) that was dismissed for failure to show convincing proof of ownership and whose dismissal was affirmed on appeal and finally closed.
RTC Ruling
The Regional Trial Court, Branch 61, Baguio City, issued an Order dated October 10, 2005 dismissing Civil Case No. 5881‑R on three grounds: (a) lack of authority to adjudicate the matter; (b) the Deeds of Sale could not yet be treated as title given respondents’ failure to perfect title or assert ownership/possession for 27 years; and (c) the complaint was barred by res judicata given the final decision in Civil Case No. 3934‑R.
Court of Appeals Ruling
The Court of Appeals, by Decision dated March 19, 2009, set aside the RTC’s dismissal and remanded the case for trial. The CA held that Civil Case No. 3934‑R (an action for injunction) and Civil Case No. 5881‑R (an action to quiet title) were different in nature, and thus res judicata did not bar the latter suit despite involving the same properties. On laches/prescription, the CA noted respondents’ allegation of possession since 1976 and concluded the action to quiet title was imprescriptible. The CA denied petitioners’ motion for reconsideration by Resolution dated September 3, 2009.
Issue Presented to the Supreme Court
Whether the Court of Appeals correctly set aside the RTC Branch 61 dismissal of Civil Case No. 5881‑R and properly remanded the case for trial.
Supreme Court’s Primary Holding
The petition was granted. The Supreme Court found the CA’s decision meritorious to reverse because the CA omitted analysis of the threshold issue of subject‑matter jurisdiction. Jurisdiction is fundamental and, where absent, the only proper action is dismissal; judgments or proceedings rendered without jurisdiction are null and void.
Supreme Court’s Analysis on Jurisdiction and PD 1271
The Court examined the nature of the subject lands and the relevant statutory framework. The parcel in question forms part of the Baguio Townsite Reservation; portions were purportedly awarded to Iloc Bilag pursuant to reopening of Civil Reservation Case No. 1, GLRO Record No. 211. PD 1271 expressly declared null and void all orders and decisions issued by the Court of First Instance of Baguio and Benguet in connection with the reopening of that case insofar as they decreed lands within the Baguio Townsite Reservation in favor of private individuals. PD 1271 provides a limited validation mechanism only for certificates of title issued on or before July 31, 1973, subject to specific conditions. The records showed the subject lands were untitled and
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Nature of Case and Procedural Posture
- Petition for review on certiorari assails: Decision dated March 19, 2009 and Resolution dated September 3, 2009 of the Court of Appeals (CA) in CA-G.R. CV No. 86266, which set aside the RTC Branch 61 Order dated October 10, 2005 and remanded the case for trial.
- Original action: Complaint for Quieting of Title with Prayer for Preliminary Injunction filed August 12, 2004 before the Regional Trial Court, Baguio City, Branch 61, docketed as Civil Case No. 5881-R.
- Parties: Petitioners are Bernadette S. Bilag, Erlinda Bilag-Santillan, Dixon Bilag, Reynaldo B. Suello, heirs of Lourdes S. Bilag, heirs of Leticia Bilag-Hanaoka, and heirs of Nellie Bilag. Respondents are Estela Ay-Ay, Andres Acop, Jr., Felicitas Ap-Ap, Sergio Ap-Ap, John Napoleon A. Ramirez, Jr., and Ma. Teresa A. Ramirez.
- Supreme Court resolution: Petition granted; CA Decision and Resolution reversed and set aside; Civil Case No. 5881-R dismissed for lack of jurisdiction of RTC Branch 61.
Relevant Facts
- The subject lands form part of a 159,496-square meter parcel designated by the Bureau of Lands as Approved Plan No. 544367, Psu 189147, situated at Sitio Benin, Baguio City.
- Respondents allege Iloc Bilag (petitioners’ predecessor-in-interest) sold to them, separately, various portions of the 159,496-square meter parcel and that Deeds of Sale were registered with the Register of Deeds of Baguio City.
- Respondents allege Iloc Bilag acknowledged full payment, guaranteed heirs/successors/executors to be bound by the sales, caused subject lands to be removed from Ancestral Land Claims, delivered possession in 1976, and respondents developed improvements thereon.
- Petitioners allegedly refused to honor the sales, asserted adverse rights, harassed respondents, and threatened demolition and dispossession, prompting respondents to seek quieting of title and removal of cloud on ownership and possession.
Petitioners’ Motion to Dismiss (grounds argued)
- Jurisdiction: Petitioners contended the subject lands are untitled, unregistered, and part of the Baguio Townsite Reservation (public domain), and that the RTC lacked jurisdiction because the Land Management Bureau (formerly Bureau of Lands) has authority to determine ownership over unregistered public lands.
- Prescription / Laches / Estoppel: Petitioners argued respondents waited more than 27 years from the execution of the Deeds of Sale to enforce them, thus the action was barred by prescription and/or laches.
- Res judicata: Petitioners pointed to a prior case, Civil Case No. 3934-R filed January 27, 1998 before RTC Branch 5 by respondents, where respondents asserted ownership over the same subject lands; RTC Branch 5 dismissed Civil Case No. 3934-R for lack of merit due to respondents’ failure to show convincing proof of ownership, and the dismissal was affirmed by the CA. Petitioners argued the final and executory ruling in Civil Case No. 3934-R barred the present action by res judicata.
RTC Branch 61 Order (October 10, 2005)
- RTC Branch 61 granted petitioners’ Motion to Dismiss and ordered dismissal of Civil Case No. 5881-R on the following grounds:
- Lack of authority/jurisdiction to adjudicate the action.
- The Deeds of Sale in respondents’ favor could not yet be considered title to the subject lands, noting respondents’ failure to perfect title or assert ownership and possession for 27 years.
- The present filing is barred by res judicata in view of the final and executory Decision dismissing Civil Case No. 3934-R, where respondents similarly sought declaration of ownership.
Court of Appeals Decision (March 19, 2009) and Resolution (September 3, 2009)
- The CA set aside the RTC dismissal and remanded the case to the court a quo for trial.
- Res judicata: The CA held Civil Case No. 3934-R was an action for injunction to enjoin petitioners’ alleged entry and improvements, whereas Civil Case No. 5881-R is an action to quiet title seeking removal of cloud on ownership and possession; although involving the same property, the CA found the nature of actions differed and res judicata did not apply.
- Prescription / Laches / Estoppel: The CA observed respond