Republic v. Reyes
REITERATIONFacts
The Antecedents: Respondents Urbano C. Lara and Godofredo R. Eusebio were issued Free Patent Nos. V-45853 and V-45854, respectively, along with Original Certificates of Title Nos. 140 and 139, for parcels of land in Napindan, Taguig, Rizal. Subsequent investigation by the Bureau of Lands revealed these lands were part of Laguna de Bay and showed no signs of cultivation or occupation. Both respondents admitted non-compliance with the Public Land Act and agreed to the cancellation of their patents and titles. Procedural History: The Republic of the Philippines, through the Director of Lands, filed Civil Cases Nos. 6747 and 6748 to cancel the patents and titles. After the respondents defaulted, the Court of First Instance of Rizal rendered decisions on October 6, 1962, declaring the patents and titles null and void. These decisions became final and executory. However, on June 3, 1967, Lara and Eusebio filed Civil Case No. 10047 to annul the previous decisions, alleging lack of jurisdiction and fraud. The Court of First Instance of Rizal, Branch VI, initially declared the Director of Lands in default and, on July 6, 1967, rendered a decision nullifying the prior judgments and ordering the reinstatement of the patents and titles. Subsequently, the Director of Lands filed a Motion to Admit Petition to Reopen Proceedings, which was initially granted but later set aside by the same court on December 16, 1968, denying the motion to reopen. The Petition: The Republic of the Philippines, represented by the Director of Lands, filed this petition for certiorari with preliminary injunction seeking to annul the December 16, 1968 order of the Court of First Instance of Rizal, Branch VI. The petitioner argues that the respondent judge committed grave abuse of discretion by taking cognizance of Civil Case No. 10047, declaring the Director of Lands in default without proper service of summons, setting aside final and executory decisions, and denying the petition to reopen proceedings after initially granting it. The core of the petition is that a final and executed judgment cannot be annulled on grounds of lack of jurisdiction or fraud, especially when the lands in question are non-disposable public lands.
Issue(s)
Whether the Court of First Instance of Rizal, Branch VI, committed grave abuse of discretion in taking cognizance of Civil Case No. 10047 and annulling the final and executory decisions in Civil Cases Nos. 6747 and 6748. Whether the CFI acquired jurisdiction over the persons of the defendants in Civil Cases Nos. 6747 and 6748. Whether the decisions in Civil Cases Nos. 6747 and 6748 were procured through fraud. Whether the CFI, Branch VI, could annul the judgment of the CFI, Branch II, of the same court. Whether the subsequent transferees and mortgagee are buyers in good faith and for value.
Ruling
The petition is impressed with merit. The decision dated July 6, 1967, and the order dated December 16, 1968, are REVERSED and SET ASIDE. The decisions in Civil Cases Nos. 6747 and 6748 dated October 6, 1962, are reinstated. The Register of Deeds of Rizal is directed to cancel all Certificates of Titles issued in connection with the proceedings in Civil Case No. 10047. The real estate mortgage executed by the respondent spouses Orosa in favor of the Philippine Commercial and Industrial Bank is SET ASIDE, but their indebtedness must be paid to the Bank.
Ratio Decidendi
On the grave abuse of discretion and annulment of final judgments: The Supreme Court held that the CFI, Branch VI, committed grave abuse of discretion in taking cognizance of Civil Case No. 10047 and annulling the final and executory decisions in Civil Cases Nos. 6747 and 6748. The Court emphasized the doctrine of res judicata, stating that once a judgment becomes final and executory, the issues therein are laid to rest and cannot be reopened, especially absent a showing of deprivation of due process or extrinsic fraud. The Court reiterated that the execution of a final judgment is a ministerial duty. The filing of Civil Case No. 10047 after five years, without availing of available remedies, was deemed improper. The principle of finality of judgment is grounded on public policy and sound practice, ensuring that judgments become final at a definite date. The Court cited Bayer Philippines, Inc. vs. Agana and Malia v. IAC to support the finality of judgments and the lack of jurisdiction to alter them once they become final. On jurisdiction over the persons of the defendants: The Court found that jurisdiction was acquired over the persons of respondents Godofredo R. Eusebio and Urbano C. Lara in Civil Cases Nos. 6747 and 6748. The Sheriff's returns clearly indicated personal service of summons and copies of the complaints upon them at their recorded addresses. The Court noted the presumption of regularity in the performance of duty by the deputy sheriff. Furthermore, the records showed that the respondents were aware of the proceedings, as evidenced by their receipt of copies of the decisions and their communication with the Register of Deeds regarding the surrender of their owner's duplicate certificates. The Court cited Fuentes vs. Bautista for the principle that jurisdiction over a defendant is acquired upon actual receipt of summons. On fraud: The Court found no evidence that the decisions in Civil Cases Nos. 6747 and 6748 were procured through extrinsic or collateral fraud. The respondents' claim of lack of knowledge of the proceedings was contradicted by the evidence of proper service of summons and subsequent communications. The Court reiterated that a judgment can only be set aside on grounds of fraud if it is extrinsic or collateral, meaning fraud that prevented a party from having his day in court, which was not established in this case. On the doctrine of non-interference and co-equal branches: The Supreme Court stressed the elementary principle of non-interference, stating that a judgment of a court of competent jurisdiction cannot be opened, modified, or vacated by any court of concurrent jurisdiction. The Court cited Mas v. Dumara-og and Cabigo v. Del Rosario, holding that a judge of one branch of the Court of First Instance cannot annul the order of a judge of another branch of the same court. Doing so constitutes exceeding jurisdiction or acting with grave abuse of discretion amounting to lack of jurisdiction. The Court also referenced Article VIII, Section 5 of the 1987 Constitution, which grants the Supreme Court exclusive jurisdiction to review final judgments of inferior courts. On subsequent transferees and mortgagee: The Court ruled that the subsequent transferees (spouses Orosa, Venezuela, Cenidoza) and the mortgagee (Philippine Commercial and Industrial Bank) were not protected as buyers in good faith and for value. The Court noted that the sales occurred even before the promulgation of the decision in Civil Case No. 10047, and while the original patents and titles were still cancelled. The Court reiterated the principle that titles issued on non-disposable lots, even in the hands of an innocent purchaser for value, are subject to cancellation. The free patents and titles in question covered areas forming part of Laguna de Bay, which are neither agricultural nor disposable. The Court cited Republic v. Court of Appeals, Chacon Enterprises v. Court of Appeals, and De Leon v. Abanilla to support the cancellation of titles obtained through fraud and misrepresentation, and that a certificate of title cannot shield fraud. While acknowledging the general rule that banks are not required to investigate titles extensively, the Court found that the law on innocent purchasers for value does not apply to non-disposable public lands.
Main Doctrine
A judgment that has long become final and executory, absent a showing of deprivation of due process or extrinsic fraud, cannot be annulled by a court of concurrent jurisdiction. Furthermore, co-equal branches of the same court cannot interfere with each other's judgments.