Case Summary (G.R. No. L-10091)
Key Dates
- August 25, 1977: Ramon filed a petition for reconstitution of the lost OCT.
- January 20, 1978: Court of First Instance (CFI) Order granting the petition and ordering reconstitution and issuance of a new title in Ramon’s name.
- April 4, 1978: Transfer Certificate of Title (TCT) No. 3153 issued in Ramon’s name.
- August 29, 2012: Petition for annulment of TCT No. 3153 and related reliefs filed by petitioners.
- February 22, 2013 and April 15, 2013: Orders of the Regional Trial Court (RTC) addressing defenses and denying reconsideration.
- May 9, 2014: RTC Order declaring the CFI Order valid only as to reconstitution but void insofar as issuance of TCT No. 3153.
- April 29, 2016 and November 23, 2016: Court of Appeals (CA) decision and resolution, respectively, reversing the RTC and dismissing the annulment action.
Applicable Law and Authorities
The constitutional framework applied is the 1987 Philippine Constitution. The central jurisprudential doctrine applied is the doctrine of judicial stability or non-interference between coordinate courts, which bars one co-equal court from annulling, amending or modifying the judgment of another court of competent jurisdiction. Statutory authority cited includes Section 9(2) of Batasang Pambansa Blg. 129 granting the Court of Appeals exclusive original jurisdiction over actions for annulment of judgments of Regional Trial Courts. The decision also relies on prior precedents addressing non-interference (cases cited in the record include Pinausukan Seafood House Roxas Blvd., Inc. v. Far East Bank & Trust Company; Panlilio v. Judge Salonga; Adlawan v. Joaquino; and Springfield Development Corporation, Inc. v. Hon. Presiding Judge of RTC, Misamis Oriental, Br. 40).
Factual and Transactional Background
Ramon sought reconstitution of the lost OCT covering the family property. The CFI granted reconstitution and ordered the Register of Deeds to cancel the lost title and issue a new title in Ramon’s name based on the decree of registration. After issuance of TCT No. 3153 in Ramon’s name, tensions among siblings prompted an Agreement of Partition intended to protect each sibling’s share notwithstanding the title issued in Ramon’s name. Subsequently DAR placed part of the land under Operation Land Transfer pursuant to PD No. 27 and distributed portions to farmer-beneficiaries, with only Ramon receiving just compensation for the expropriated portion. Possession of the siblings’ agreed portions was not disturbed but a descendant of Ramon later asserted exclusive ownership.
Pleadings and Lower Court Rulings
Petitioners filed a complaint for annulment of title, enforcement of the partition agreement, reconveyance with damages, and injunctive relief. Only Remigio and Antonio (heirs of Ramon) answered. The RTC initially resolved defenses and, in its February 22, 2013 Order, declared the CFI Order invalid insofar as it ordered issuance of a new certificate of title for want of jurisdiction; the RTC denied reconsideration on April 15, 2013. Petitioners moved for summary judgment. In the May 9, 2014 RTC Order, the RTC refined its ruling: it declared the January 20, 1978 CFI Order valid only as to reconstitution but held the issuance of TCT No. 3153 in Ramon’s name void for want of jurisdiction.
Court of Appeals Proceedings and Ruling
Antonio and Remigio appealed, and the CA consolidated the appeal with a related certiorari matter. The CA applied the doctrine of non-interference between coordinate courts and concluded that the RTC erred in declaring the CFI Order void. The CA held that the RTC had no authority to annul or modify the judgment of a co-equal court (the CFI) and thus reversed the RTC’s orders and dismissed the complaint for annulment of TCT No. 3153.
Supreme Court Issue Presented
The sole issue presented for review was whether the Court of Appeals erred in dismissing petitioners’ complaint for annulment of title by applying the doctrine of non-interference (judicial stability) to shield the CFI Order from attack in a different trial court.
Supreme Court’s Legal Analysis on Non-Interference
The Court reiterated the doctrine of judicial stability: a judgment of a court of competent jurisdiction cannot be interfered with by another court of concurrent jurisdiction. The doctrine rests on jurisdictional principles and precludes a co-equal court from altering, amending or declaring void the judgment of another co
...continue readingCase Syllabus (G.R. No. L-10091)
Case Citation and Court
- Full citation: 861 Phil. 68, Second Division, G.R. Nos. 229164 & 229186, September 02, 2019.
- Decision authored by Justice Reyes, Jr., J., with concurrence by Carpio (Chairperson), Caguioa, Lazaro-Javier, and Zalameda, JJ.
- The petition is a Petition for Review on Certiorari from the Court of Appeals decision dated April 29, 2016 and Resolution dated November 23, 2016 in CA-G.R. CV No. 102933.
Parties and Their Roles
- Petitioners:
- Mercedes Tolentino Soliman.
- Heirs of Angeles Tolentino—Gracia S. Panes, Edgar T. Salvosa, Benjamin T. Salvosa, Sonia I. Mendoza.
- Heirs of Rafael Tolentino—Leah T. Baena, Rene Angel T. Tolentino, Robert T. Tolentino.
- Collectively referred to in the decision as "petitioners."
- Respondents:
- Heirs of Ramon Tolentino—Marilou T. Loiue, Antonio I. Tolentino, Elsa T. Calaustro, Dolores T. Tolentino, Jocelyn T. Duran, Teresita T. Thomas, Susan T. Clasio, and Remigio Manchus.
- Key individual family members:
- Spouses Doroteo Tolentino and Engracia Dela Cruz: original registered owners of the subject land.
- Children of spouses Tolentino: Ramon, Angeles, Rafael, Carmen T. Imperial, Mercedes.
- Ramon Tolentino: petitioner in reconstitution of title proceedings; later the named owner under TCT No. 3153.
- Remigio Manchus and Antonio Tolentino: among Ramon’s heirs who filed answers and appeals.
Property at Issue
- Parcel size and location: 200,944 square meters situated in San Vicente, Pili, Camarines Sur.
- Original title: Original Certificate of Title (OCT) No. RO 529 (263) held in the names of the late spouses Doroteo Tolentino and Engracia de la Cruz.
Factual Background and Genesis of the Dispute
- Loss of original title: The OCT No. RO 529 (263) was alleged lost and destroyed.
- Reconstitution petition: On August 25, 1977, Ramon filed a petition for reconstitution of the lost OCT before the Court of First Instance (CFI) of Pili, Camarines Sur, Branch VI, and prayed that the reconstituted title be issued in his name.
- CFI Order of January 20, 1978:
- The CFI granted the petition and declared the original and owner’s duplicate copies of OCT No. 263 in the names of the late spouses as lost and of no legal force.
- The Register of Deeds was ordered to reconstitute the title based on the decree of registration and thereafter cancel the same and issue, in lieu thereof, a new title in the name of the petitioner, Dr. Ramon Tolentino, subject to such encumbrances as may be found subsisting.
- The CFI order is recorded in the decision as penned by Judge Esteban Lising.
- Issuance of title: On April 4, 1978, Transfer Certificate of Title (TCT) No. 3153 was issued in the name of Ramon.
- Family understanding and subsequent partition agreement:
- Petitioners (siblings and heirs of Angeles and Rafael, and Mercedes) contended the land was co-owned as heirs of the spouses Tolentino.
- Following the issuance of TCT No. 3153 in Ramon’s name, the siblings confronted one another; Ramon allegedly assured them their shares would be protected despite the single-title issuance.
- An Agreement of Partition was executed among the siblings, allocating particular portions of the property to each sibling; petitioners maintained possession of their respective portions and asserted their co-ownership was terminated by this Agreement.
- Agrarian intervention:
- The Department of Agrarian Reform (DAR) placed a portion of the land under Operation Land Transfer pursuant to Presidential Decree No. 27 and distributed the same to farmer-beneficiaries.
- Only Ramon allegedly received just compensation corresponding to the expropriated land.
- Change in position by some heirs: Subsequently, one of Ramon’s heirs began claiming exclusive ownership in their father and refused to acknowledge the sibling Agreement of Partition.
- Parties who filed answers: Only Remigio Manchus and Antonio Tolentino filed an Answer with Special and Affirmative Defenses asserting Ramon’s exclusive ownership upon the death of spouses Tolentino because the other siblings were allegedly given their respective properties elsewhere.
Procedural History — Trial Court and Motions
- Petition for annulment and related reliefs: On August 29, 2012, petitioners filed a petition for annulment of TCT No. 3153, enforcement of agreement of partition, reconveyance with damages, and sought a temporary restraining order and preliminary mandatory injunction against the heirs of Ramon.
- Motion for Summary Judgment: On June 10, 2013, petitioners filed a Motion for Summary Judgment seeking a judgment on the validity of the CFI Order of January 20, 1978 and the issuance of TCT No. 3153.
- RTC Orders:
- RTC Order of February 22, 2013: The Regional Trial Court (RTC), Branch 33, Pili, Camarines Sur, resolved defenses of Ramon’s heirs and explicitly ruled the CFI Order invalid insofar as issuance of a title in favor of Ramon for want of jurisdiction (order penned by Judge Marvel C. Clavecilla).
- Denial of Motion for Reconsideration: Remigio and Antonio’s motion for reconsideration was denied by RTC in an Order dated April 15, 2013.
- RTC Order of May 9, 2014: The RTC declared the January 20, 1978 CFI Order valid only with respect to the reconstitution of title but declared the issuance of TCT No. 3153 in Ramon’s name void for want of jurisdiction. The decision language: (a) the Order of January 20, 1978 relative to the reconstitution and cancellation of OCT No. RO-529(263) in the name of spouses Doroteo Tolentino and Engracia [Dela] Cruz is VALID and (b) the issuance of a Transfer Certificate of Title No. 3153 in the name of Ramon Tolentino, in lieu of OCT No. RO-259(263) is VOID, for having been issued for want of jurisdiction.
Appeals and Proceedings in the Court of Appeals
- Appeals and consolidation:
- Antonio and Remigio appealed the RTC Order (docketed as CA-G.R. CV No. 102933), contending the RTC lacked authority to annul, amend, or modify the CFI Order dated January 20, 1978.
- The Court of Appeals consolidated Antonio and Remigio’s appeal with their Petition for Certiorari (CA-G.R. SP No. 130055).
- CA Decision dated April 29, 2016:
- Applying the doctrine of non-interference (judicial stability), the Court of Appeals held that the RTC erred in declaring the CFI Order void because the CFI was a co-equal court whose judgme