Case Summary (G.R. No. 182434)
Procedural History and Legislative Framework
The private respondents filed the suit for quieting of title on February 21, 1997, before the SDC. Petitioner denied their ownership claim and moved to dismiss based on the lack of jurisdiction of the SDC, citing Batas Pambansa Blg. 129 (BP 129) or the Judiciary Reorganization Act of 1980, which vests exclusive original jurisdiction over civil actions involving title or possession of real property on regular civil courts (RTC or MTCs). The SDC denied the motions to dismiss, asserting its original and concurrent jurisdiction under Article 143, paragraph 2(b) of Presidential Decree No. 1083 (PD 1083), known as the Code of Muslim Personal Laws, which grants Shari'a courts jurisdiction over personal and real property actions involving Muslims. Petitioner’s motion for reconsideration was also denied, prompting a petition for certiorari before the Court of Appeals (CA), which dismissed it for lack of jurisdiction, directing eventual recourse to the Supreme Court pending organization of the Shari'a Appellate Court.
Jurisdictional Conflict: BP 129 vs. PD 1083
Petitioner argued that Section 19(2) of BP 129, as amended, confers exclusive jurisdiction to RTCs or MTCs over civil cases involving title or possession of real property, effectively repealing the concurrent jurisdiction previously afforded the SDC under Article 143(2)(b) of PD 1083. Private respondents countered that PD 1083 is a special law specifically applicable to Muslims and the Shari'a courts, which must prevail over the general law (BP 129) unless expressly repealed. The jurisprudential principle applied is generalia specialibus non derogant, meaning that a general law does not derogate a special law unless there's an express repeal, which was absent in this case.
Analysis of SDC Jurisdiction
Preceding BP 129, under the Judiciary Act of 1948 (RA 296), regular courts had original jurisdiction over real property cases. The creation of Shari'a courts under PD 1083 vested certain exclusive and concurrent jurisdiction to SDCs over civil cases involving Muslim parties, including personal and real actions not covered by exclusive exceptions. BP 129 reorganized the judiciary's civil courts but did not include Shari'a courts in its scope.
Interpretation of BP 129’s provisions excludes Shari'a courts from its reorganization, implying that the concurrent jurisdiction of the SDC over real property cases involving Muslims continues to co-exist with RTC jurisdiction. Article 143(2)(b) of PD 1083 thus remains effective, giving the Shari'a District Courts concurrent original jurisdiction with civil courts over real and personal actions involving Muslim parties, except for forcible entry and unlawful detainer cases.
Distinction Between Personal and Real Action
Consistent with jurisprudence, a personal action arises out of contracts and seeks enforcement or recovery of personal property, while a real action seeks recovery of ownership or possession of real property or interests therein. The private respondents’ complaint, alleging absolute ownership and illegal dispossession, properly pleads a real action for reconveyance—a cause of action within SDC’s jurisdiction under PD 1083 when parties are Muslims.
Supreme Court’s Position on Jurisdiction and Repeal Doctrine
The Court held that BP 129, as a general law, does not repeal the special law (PD 1083) establishing Shari'a courts’ jurisdiction over personal and real actions involving Muslims. Since no express repeal exists, jurisdiction granted to SDCs under PD 1083 persists concurrently with that of regular courts. The Court emphasized the need to harmonize the two laws and applied the maxim that general laws yield to special laws in case of conflict. Hence, the shari'a courts’ jurisdiction over the case remains valid.
Jurisdiction is determined from the complaint's allegations and relief sought, not from defenses or motions filed by the parties. The complaint’s proper assertions vested jurisdiction in the SDC.
Admonition Against Abuse of Procedural Rights
The Court condemned petitione
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Case Syllabus (G.R. No. 182434)
Background and Procedural History
- Private respondents Amna A. Pumbaya, Jalilah A. Mangompia, and Ramla A. Musor, daughters and legal heirs of the late Acraman Radia, filed a case for quieting of title over a parcel of land in Banggolo, Marawi City, against petitioner Sultan Yahya "Jerry" M. Tomawis and Mangoda Radia.
- The complaint alleged their absolute ownership of the disputed land based on their inheritance and possession; Tomawis' claim to the land was based on a purported purchase from Mangoda Radia.
- They claimed unlawful deprivation of possession when Tomawis allegedly ordered the leveling of the property and removal of their small houses in 1996, causing a cloud on their title.
- Tomawis filed an answer contending lack of jurisdiction by the Shari’a District Court (SDC), arguing that regular civil courts have exclusive jurisdiction over title and possession cases under Batas Pambansa Blg. 129 (BP 129).
- The SDC, through Judge Rasad Balindong, denied Tomawis' motion to dismiss and subsequent motions challenging jurisdiction.
- Tomawis prayed for certiorari, prohibition, and mandamus before the Court of Appeals (CA) to nullify the SDC orders based on jurisdictional grounds.
- The CA dismissed the petition citing lack of power to review SDC decisions, directing that appeals lie with the yet-unorganized Shari’a Appellate Court or with the Supreme Court.
- Eventually, pursuant to procedural recalcitrance by petitioner, this case reached the Supreme Court raising exclusively the issue of jurisdiction of the SDC over Civil Case No. 102-97.
Issue Presented
- Whether the Shari’a District Court, Fourth Judicial District in Marawi City, acted with grave abuse of discretion in denying petitioner Sultan Yahya "Jerry" M. Tomawis' motions to dismiss for lack of jurisdiction over the civil case involving the quieting of title and possession of real property.
Relevant Legal Framework
- PD 1083 (Code of Muslim Personal Laws of the Philippines) established Shari’a courts (SDC and Circuit Courts) with limited original jurisdiction over cases involving Muslims.
- Article 143, paragraph 2(b) of PD 1083 confers concurrent original jurisdiction to the SDC with civil courts over personal and real actions involving Muslim parties, except those of forcible entry and unlawful detainer.
- Batas Pambansa Blg. 129 (Judiciary Reorganization Act of 1980), as amended by RA 7691, vests exclusive original jurisdiction over civil actions involving title or possession of real property to Regional Trial Courts (RTC) or Municipal Trial Courts (MTC), depending on the assessed value.
- Republic Act No. 9054 (Organic Law of the Autonomous Region in Muslim Mindanao