Title
Tomas Claudio Memorial College, Inc. vs. Court of Appeals
Case
G.R. No. 124262
Decision Date
Oct 12, 1999
Heirs sought partition of land sold by co-owner without consent; SC upheld imprescriptibility of partition, affirmed jurisdiction, denied res judicata.
jurisdiction
disputed land sale
certiorari
A

Case Summary (G.R. No. 124262)

Petitioner

Tomas Claudio Memorial College, Inc. defended the sale and opposed partition; it moved to dismiss on grounds including lack of jurisdiction and prescription/laches, and later sought relief by elevated proceedings to the Court of Appeals and ultimately to the Supreme Court by certiorari.

Respondents

Regional Trial Court (Branch 79), Morong, Rizal (trial court that heard the partition action); Court of Appeals (respondent public body in the special civil action); private respondents (the heirs who filed the partition case).

Key Dates and Procedural Milestones

  • 1979: Alleged sale of Lot No. 3010 by Mariano to petitioner.
  • December 13, 1993: Private respondents filed an action for partition in the RTC of Morong, Rizal.
  • August 18, 1984: Trial court initially dismissed the complaint (date as stated in the record).
  • October 4, 1994: Trial court set aside its prior dismissal and took cognizance of the partition action.
  • January 5, 1995: Trial court denied petitioner’s motion for reconsideration.
  • August 14, 1995: Court of Appeals dismissed petitioner’s special civil action for certiorari.
  • March 15, 1996: Court of Appeals denied petitioner’s motion for reconsideration.
  • October 12, 1999: Supreme Court issued the challenged decision (affirming the CA).

Applicable Law and Governing Framework

Governing constitution: 1987 Philippine Constitution (applicable because the decision date is after 1990). Procedural and substantive authorities relied upon in the decision include Rule 65 of the Rules of Court (special civil action for certiorari), and Civil Code provisions governing co-ownership and disposition of undivided interests (Articles 493 and 494). The decision also applies established jurisprudential standards on certiorari and grave abuse of discretion.

Nature of Relief Sought and Legal Grounds Advanced by Petitioner

Petitioner invoked Rule 65 certiorari to challenge the Court of Appeals’ affirmance of the RTC’s decision to proceed with the partition action. Principal grounds advanced: (1) lack of jurisdiction because causes of action were allegedly already finally decided by a prior case; (2) grave abuse of discretion by the RTC and CA in taking cognizance and proceeding with the case despite asserted res judicata and prior final determinations; and (3) prescription and/or laches as a defense to the partition action.

Issues Presented for Resolution

The Supreme Court framed the pivotal issues as: (1) whether the RTC and/or the Court of Appeals had jurisdiction over the partition action; and (2) if jurisdiction existed, whether the Court of Appeals committed grave abuse of discretion in affirming the RTC’s taking of the case.

Standard for Granting Certiorari and Meaning of Grave Abuse of Discretion

The Court reiterated the exacting standard for Rule 65 certiorari: relief is available only where the respondent court committed grave abuse of discretion tantamount to lack or excess of jurisdiction. Mere errors of judgment, procedural errors, or incorrect applications of law that do not amount to capricious and whimsical exercise of power are not correctible by certiorari; such errors are reviewable by appeal. Grave abuse implies an arbitrary or despotic exercise of judgment equivalent to lack of jurisdiction.

Jurisdiction Over the Subject Matter and Its Determination

The Supreme Court explained that jurisdiction over the subject matter is conferred by law and is determined by the allegations of the complaint, not by defenses set up by the defendant. Thus, when the RTC took cognizance of the partition complaint, it lawfully acquired jurisdiction over the subject matter because the complaint’s allegations invoked the court’s competence. A defendant’s contention that a prior adjudication bars the action does not negate the trial court’s subject-matter jurisdiction; rather, it raises defenses or issues of res judicata that the trial court must resolve in the ordinary course. Even if the lower courts erred in resolving those defenses, such errors constitute reviewable errors of judgment rather than the kind of grave abuse correctible by certiorari.

Waiver of Objections to Jurisdiction by Seeking Relief and Submission to Jurisdiction

The Court observed that petitioner itself sought relief from the Court of Appeals by filing the certiorari petition, thereby invoking the appellate court’s jurisdiction. A party that invokes or submits to a court’s jurisdiction cannot thereafter challenge that court’s jurisdiction in the same case. The Supreme Court held that petitioner’s act of seeking relief before the Court of Appeals amounted to submission and foreclosed a belated challenge to that court’s jurisdiction.

Legal Effect of a Co-Owner’s Sale and Proper Form of Action

Under Article 493 (as applied in the decision) a co-owner may sell his undivided share; such sale affects only the seller’s pro indiviso share. The buyer acquires only the seller’s undivided portion and thus becomes a co-owner with the remaining co-owners. A sale by one co-owner without the consent of other co-owners is not void; it merely transfers the sel

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