Case Summary (G.R. No. 217120)
Background of the Case
The petition arose from a decision of the Court of Appeals (CA) dated February 20, 2015, which denied the Republic's petition for certiorari that aimed to annul the orders issued by the Regional Trial Court (RTC), Branch 57, admitting the Amended and Supplemental Petition of the respondents. This petition sought the cancellation of lis pendens annotated on the subject TCTs and a quieting of title, asserting that these claims had prescribed due to the Republic’s failure to act on a long-standing judgment regarding the properties.
Historical Proceedings
The original legal proceedings date back to 1960, when criminal cases were filed against Florentino Molinyawe for malversation. Subsequently, the Republic initiated a forfeiture case under Republic Act No. 1379, arguing that Florentino had illegally acquired assets inconsistent with his declared income. The forfeiture was adjudicated by the then Court of First Instance of Pasig, which declared sales of the properties null and void and ordered forfeiture to the Republic. This judgment became final in 1974, yet execution was notably delayed.
Proceedings in Lower Courts
Years later, in 2010, the respondents filed a complaint in RTC-Branch 57 seeking the cancellation of the lis pendens and quieting of title on grounds that the original judgment in the forfeiture case was not acted upon by the Republic. The RTC granted their petition to amend their original complaint, which was contested by the Republic on several jurisdictional grounds.
Court of Appeals Ruling
The CA dismissed the Republic's petition, concluding that RTC-Branch 57 retained jurisdiction over quieting of title actions, and that the amendment of the petition did not equate to grave abuse of discretion. The CA suggested that despite the procedural improprieties, the RTC's actions did not meet the threshold for certiorari due to the lack of capriciousness or whimsy in its judgments.
Republic's Arguments
In its petition before the Supreme Court, the Republic contended that the RTC-Branch 57 lacked jurisdiction over Civil Case No. 10-658, as it was intertwined with a final and executory decision from a co-equal court regarding the same properties. The Republic asserted that the amended petition represented a collateral attack on the final judgment in the forfeiture case, thus the RTC's actions were irreparably flawed.
Respondents' Position
The respondents countered that RTC-Branch 57 had proper jurisdiction and that the amendments sought were valid under the Rules of Court. They maintained that their actions for quieting of title were distinct and incapable of pecuniary estimation, thus justifying the RTC's jurisdiction.
Supreme Court's Ruling
The Supreme Court held that the Republic's petition was meritorious, empha
...continue readingCase Syllabus (G.R. No. 217120)
Introduction
- This case involves a petition for review on certiorari filed by the Republic of the Philippines, seeking to reverse the February 20, 2015 Decision of the Court of Appeals (CA) that denied the Republic's petition for certiorari.
- The original dispute revolves around Civil Case No. 10-658, pending before the Regional Trial Court (RTC), Branch 57, Makati City, concerning the cancellation of lis pendens and the quieting of title over certain Transfer Certificates of Title (TCTs).
Antecedents
- Criminal cases for malversation were filed against Florentino Molinyawe and others in 1960, alongside a forfeiture case by the Republic under Republic Act No. 1379.
- The forfeiture case involved properties registered under TCT Nos. 75239, 76129, and 77577, which the Republic claimed were illegally acquired due to the disparity between their value and Florentino's declared income.
- The CFI-Pasig declared the sale of the properties void and ordered their forfeiture in favor of the Republic in a decision made on September 22, 1972, which became final and executory in 1974.
- After several years, the respondents, as heirs of Florentino, filed a complaint in 2010 for the cancellation of the lis pendens and quieting of title, asserting that the Republic had failed to execute the final judgment regarding the forfeiture.
Procedural History
- The RTC-Branch 57 admitted the respondents’ amended petition, which led the Republic to file a motion f