Philippine National Bank v. Florendo
REITERATIONFacts
The Antecedents: Plaintiffs, tenants of four parcels of land in Mabinay, Negros Oriental, filed a complaint for the declaration of nullity of foreclosure proceedings initiated by the Philippine National Bank (PNB). These lands were previously owned by Ricardo Valeroso, mortgaged to PNB, and later bought by spouses Agripino and Soledad Viloria who assumed the mortgage. PNB foreclosed the mortgage in 1974 due to unpaid amortizations and the land was sold at public auction to PNB. The lands were allegedly under the government's Land Reform Program, and PNB caused the titles to be transferred to its name, to the prejudice of the plaintiffs. Procedural History: Plaintiffs filed a complaint in the Court of Agrarian Relations (CAR) for the nullity of foreclosure proceedings in violation of P.D. Nos. 27 and 946. PNB answered with a counterclaim. Plaintiffs later moved to amend their complaint to implead heirs of a deceased plaintiff, which was admitted. Subsequently, private respondents moved to further amend their complaint to include a fifth parcel of land, identified as Lot No. 787-B-2-A (covered by TCT No. 42836), located in Cebu City, which was also mortgaged to PNB. PNB opposed this amendment, citing lack of proper notice, the inclusion of a non-agrarian land, and failure to attach the mortgage contract. The CAR judge admitted the First Amended Complaint. PNB's motion for reconsideration was denied. The Petition: PNB filed a petition for certiorari with preliminary injunction, seeking to annul the orders admitting the First Amended Complaint and denying the motion for reconsideration. The Supreme Court issued a temporary restraining order. The primary issue is whether the respondent judge exceeded his jurisdiction in admitting the First Amended Complaint which added a parcel of land not within the coverage of Operation Land Transfer under P.D. 27.
Issue(s)
Whether the respondent judge committed grave abuse of discretion amounting to excess of jurisdiction in admitting the First Amended Complaint. Whether the Court of Agrarian Relations had jurisdiction over the parcel of land located in Cebu City, which is alleged to be residential and non-agricultural.
Ruling
The petition for certiorari is granted. The orders dated May 31, June 3, and June 28, 1982, are annulled and set aside. The trial of CAR Case No. 532 is ordered to be conducted in the appropriate Branch of the Regional Trial Court of Negros Oriental, with the temporary restraining order regarding Lot No. 787-B-2-A made permanent.
Ratio Decidendi
On the issue of the propriety of admitting the First Amended Complaint: While amendments to pleadings are generally favored, the Supreme Court reiterated that such liberality does not extend to conferring jurisdiction upon a court that does not possess it. Since the CAR clearly lacked jurisdiction over the subject matter of Lot No. 787-B-2-A, the admission of the First Amended Complaint, which sought to include this non-agrarian land, was an act in excess of jurisdiction. The Court cited the principle that amendments cannot be allowed to confer jurisdiction where none exists. The subsequent abolition of the CAR by BP 129 further rendered the issue of its territorial jurisdiction moot, but the fundamental lack of jurisdiction over the subject matter remained the basis for annulling the order. The Court found the petition for certiorari to be the proper remedy. It explained that certiorari is available to keep an inferior court within the bounds of its jurisdiction and to correct defects of jurisdiction. Even if an appeal were available, the Court has allowed certiorari when orders were issued in excess of or without jurisdiction. The respondent judge's act of admitting an amended complaint that included a property over which the court had no jurisdiction was deemed an act in excess of jurisdiction, thus justifying the resort to certiorari. On the issue of jurisdiction over Lot No. 787-B-2-A: The Supreme Court held that the Court of Agrarian Relations (CAR), and by extension the Regional Trial Court acting as an agrarian court, has exclusive jurisdiction only over cases involving agricultural lands and agrarian reform matters as defined by P.D. 946. The Court noted that private respondents themselves admitted that Lot No. 787-B-2-A is a residential lot located in Cebu City. Furthermore, a certification from Agrarian Reform Team No. 215 confirmed that the said lot is not within the coverage of Operation Land Transfer pursuant to P.D. 27. The Court emphasized that jurisdiction over the subject matter is conferred by law and cannot be acquired through or conferred by the acts or omissions of the parties. Therefore, the CAR had no jurisdiction over the said residential land.
Main Doctrine
A court of agrarian relations, or its successor in interest, the Regional Trial Court acting as an agrarian court, has no jurisdiction over residential or non-agricultural lands, and an amendment to a complaint that seeks to include such lands cannot be allowed to confer jurisdiction upon the court.