Title
Malaba vs. Republic
Case
G.R. No. 201821
Decision Date
Sep 19, 2018
The Republic sought land reversion and title cancellation, claiming the land was inalienable public forest. The RTC dismissed for lack of jurisdiction, but the CA reversed, ruling it was a reversion case under RTC jurisdiction. The Supreme Court affirmed, stating jurisdiction depends on the complaint's allegations, not defenses.
reversion suit
registered owners
land

Case Summary (G.R. No. 201821)

Factual Background

The Republic commenced Civil Case No. C-192 against Angelo B. Malabanan, Pablo B. Malabanan (petitioner), and Greenthumb Realty and Development Corporation, as registered owners of various parcels covered by TCT No. T-24268 of the Registry of Deeds of Batangas. The Republic alleged that TCT No. T-24268 had emanated from OCT No. 0-17421, which was purportedly issued pursuant to Decree No. 589383 in L.R.A. Record No. 50573. The Republic further averred that, upon verification, the Land Registration Authority could not locate any copy of the decision purportedly rendered in L.R.A. Record No. 50573. It also alleged that the tract covered by TCT No. T-24268, being within the unclassified public forest of Batangas, remained part of the public domain and could not be the subject of disposition or registration.

In response, petitioner moved to dismiss on the theory that the RTC lacked jurisdiction because the complaint effectively sought the annulment of the judgment and decree issued in L.R.A. Record No. 50573, a matter petitioner claimed fell within the appellate jurisdiction of the Court of Appeals.

RTC Dismissal and the Jurisdictional Theory

On December 11, 1998, the RTC granted the motion to dismiss. It reasoned that invalidating OCT No. 0-17421 and all derivative titles would necessarily require nullifying the judgment of the Land Registration Court that decreed the issuance of the title. The RTC thus treated the case as covered by Section 9(2) of Batas Pambansa Blg. 129, which, in its view, vested exclusive jurisdiction in the Court of Appeals over actions for annulment of judgments of the RTC.

After the Republic filed a notice of appeal, petitioner and the other defendants moved to deny due course, arguing that the appeal mode was improper because the jurisdictional issue was a pure question of law cognizable by the Supreme Court on petition for review on certiorari. On June 29, 1999, the RTC denied due course and dismissed the Republic’s appeal.

The Republic then assailed the RTC order through a petition for certiorari in the CA, docketed as CA-G.R. No. SP No. 54721.

CA Reversal of the Dismissal Order

The CA promulgated its ruling on February 29, 2000, holding that determining whether an appeal could be dismissed on the ground that it involved a pure question of law was exclusively lodged in the CA as the appellate court; hence, the RTC should have given due course and transmitted the original records.

Thereafter, on May 27, 2011, the CA resolved the appeal on the merits. It set aside the RTC’s December 11, 1998 dismissal and remanded the case to the RTC with instructions for the defendants to file responsive pleadings and for the RTC to proceed with trial on the merits and resolve the case with dispatch.

CA’s Reasoning: Reversion Suits and RTC Jurisdiction

The CA held that the complaint invoked the Republic’s right to seek reversion of lands of the public domain. It found the Republic’s allegations decisive for jurisdiction: the Republic alleged that, after investigation by the Department of Environment and Natural Resources (DENR), the property covered by TCT No. 24268 was located within the unclassified public forest, rendering it inalienable. The CA emphasized that where a parcel is found to be inalienable public land under the Regalian Doctrine, the Government may file an original action for reversion.

In support, the CA invoked Section 101 of Commonwealth Act No. 141, which provides that actions for reversion to the Government of lands of the public domain shall be instituted by the Solicitor General in the name of the Republic in proper courts. The CA also reasoned that the challenged titles were not necessarily void merely because the decision purportedly in L.R.A. Record No. 50573 could not be found; rather, the proper course was to try the case and determine whether the Republic’s evidence established that the property was indeed part of the public domain and was not capable of private disposition. It further noted that the matters raised in the motion to dismiss required evidentiary determination, making trial on the merits the appropriate mode of resolution rather than dismissal.

Petitioner’s Contentions Before the Supreme Court

Petitioner maintained that the CA erred in setting aside the RTC’s dismissal and in ordering the RTC to proceed to trial. His argument centered on the nature of the relief sought: petitioner insisted that the action to annul OCT No. 0-17421 and the derivative certificates necessarily related to the final judgment of the Land Registration Court, and thus fell within the ambit of Rule 47 of the Rules of Court as an action for annulment of judgment, which petitioner claimed must be lodged in the CA.

Petitioner anchored his position on Estate of the Late Jesus S. Yujuico v. Republic, Collado v. Court of Appeals, and Republic v. Court of Appeals, arguing that the Republic should have filed a complaint for annulment of judgment pursuant to the procedural requirement under Rule 47.

Republic’s Counter-Position

The Republic responded that its complaint did not seek the annulment of a judgment because, according to its allegations, the decision purportedly issued in L.R.A. Record No. 50573 did not exist in the first place. It also argued that the nature of its action was reversion and cancellation of title within the RTC’s jurisdiction, given the alleged inalienable character of the land as unclassified public forest.

Supreme Court’s Ruling

The Supreme Court denied the petition and affirmed the CA decision dated May 27, 2011.

Legal Basis and Reasoning

The Court reiterated the controlling doctrine that jurisdiction over the subject matter is determined by the allegations in the complaint, the law in force at the time the complaint is filed, and the character of the relief sought, regardless of whether the plaintiff is entitled to all or some claims. It further held that jurisdiction is not affected by the defendant’s theory in the answer or motion to dismiss, because otherwise jurisdiction would depend on the whims of the defendant.

Applying that framework, the Court examined the material allegations in Civil Case No. C-192. It noted that the complaint alleged, among others, that: TCT No. T-24268 emanated from OCT No. 0-17421 pursuant to Decree No. 589383 in L.R.A. Record No. 50573; that no copy of the decision in L.R.A. Record No. 50573 could be found; that the land was within the unclassified public forest of Batangas; that the titles were subdivided and re-registered in several lots and names; and that the complaint sought (a) cancellation of OCT No. 0-17421 and (b) reversion to the Republic of the land covered by OCT No. 0-17421, on the grounds that there had been no decision authorizing the issuance of the title and that the land covered by TCT No. T-24268 was part of the unclassified public forest.

From these averments and reliefs, the Court held that the complaint was not an action to annul the judgment in L.R.A. Record No. 50573. The Court reasoned that the suit was properly characterized as an action for cancellation of titles and reversion, where the Republic’s ultimate relief was to revert the property to the public domain under the Regalian Doctrine.

In so ruling, the Court relied on the factual and doctrinal similarity of Republic v. Roman Catholic Archbishop of Manila, where the Court had stated that annulment of judgment under Rule 47 had no application when the prayed relief did not necessitate annulling the Land Registration Court’s judgment, and when the action sought only cancellation of titles and reversion based on the absence of the subject matter covered in the prior land registration case. The Court emphasized that in such cases, Rule 47 does not apply because the reversion action does not call for annulment of the judgment of the RTC acting as a Land Registration Court.

The Court further distinguished petitioner’s reliance on cases on annulment of judgment, including Estate of the Late Jesus S. Yujuico v. Republic, Collado v. Court of Appeals, and Republic v. Court of Appeals. It found those cases irrelevant because, therein, the Republic had instituted actions for annulment of judgment. The Republic had recognized there that the land titles were issued pursuant to final judgments rendered by the Land Registration Court and that such judgments had to be invalidated before reversion could follow. In contrast, the Republic in Civil Case No. C-192 alleged that no judgment existed in the first place, and the attack was directed to the title being cancelled in the reversion suit.

Finally, the Court clarified the nature of the attack in a reversion suit. It stated that the challenge is not directed against the judgment ordering the issuance of title but against the title sought to be cancelled

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