Tomas Claudio Memorial College, Inc. v. Court of Appeals
REITERATIONFacts
The Antecedents: Private respondents filed an action for Partition before the Regional Trial Court (RTC), alleging that their predecessor-in-interest, Juan De Castro, died intestate and they are his sole surviving heirs. They claimed that their father owned a parcel of land, Lot No. 3010, which was sold in 1979 by their brother, Mariano, to petitioner Tomas Claudio Memorial College, Inc. (TCMC). Mariano allegedly misrepresented himself as the sole heir, and the private respondents contended that the sale only affected Mariano's undivided share, not the shares of the other co-owners. Procedural History: Petitioner TCMC filed a motion to dismiss, asserting lack of jurisdiction and prescription/laches. The RTC initially dismissed the complaint but later reconsidered and set aside its dismissal order. TCMC's motion for reconsideration of this order was denied. Aggrieved, TCMC filed a special civil action for certiorari with the Court of Appeals (CA), arguing that the RTC lacked jurisdiction as the causes of action had been decided with finality by the Supreme Court and that the RTC committed grave abuse of discretion. The CA dismissed TCMC's petition, finding no grave abuse of discretion by the RTC. TCMC's motion for reconsideration was denied. The Petition: TCMC filed a special civil action for certiorari with the Supreme Court, seeking to set aside the CA's decision and resolution. TCMC argued that the RTC and CA had no jurisdiction because the causes of action were already decided with finality by the Supreme Court, and that the CA gravely abused its discretion by sustaining the RTC's orders, particularly in light of a previous ruling where TCMC was allegedly not a real party in interest in a related case. TCMC also contended that the CA capriciously disregarded the existence of res judicata.
Issue(s)
Whether the Regional Trial Court and the Court of Appeals had jurisdiction over the case and whether certiorari was the proper remedy to challenge the denial of the motion to dismiss. Whether the action for partition filed by the heirs was barred by prescription or laches following the sale of the lot in 1979.
Ruling
The petition is denied. The assailed decision of the Court of Appeals is affirmed.
Ratio Decidendi
On Issue 1: The Supreme Court held that the Regional Trial Court (RTC) correctly acquired jurisdiction over the subject matter, which is determined by the allegations in the complaint rather than the defenses raised in a motion to dismiss. A petition for certiorari under Rule 65 is intended to correct errors of jurisdiction or grave abuse of discretion, not mere errors of judgment which should be addressed via timely appeal. The Court emphasized that even if the appellate court erred in its findings, such errors are not correctible by certiorari if the court acted within its jurisdiction. Furthermore, the petitioner is estopped from questioning the jurisdiction of the Court of Appeals because it was the one that invoked said jurisdiction by filing the petition for certiorari in that court. Seeking affirmative relief from a court and subsequently challenging its jurisdiction after receiving an unfavorable ruling is a practice the Court does not tolerate as it amounts to speculating on the fortunes of litigation. On Issue 2: The Court ruled that the action for partition had not prescribed. Applying Article 493 of the Civil Code, the Court explained that a co-owner has the right to sell his undivided share, and such a sale of the entire property only transfers the rights of the co-owner/seller to the buyer. Therefore, TCMC merely became a co-owner of the property, stepping into the shoes of Mariano De Castro for his 1/5 share. Under Article 494 of the Civil Code, the right to demand partition is imprescriptible, meaning no co-owner is obliged to remain in the co-ownership and can demand division at any time. The Court reiterated the doctrine in Budlong v. Bondoc that an action for partition cannot be barred by prescription as long as the co-ownership is recognized. Thus, the private respondents, as co-owners, were well within their rights to file for partition despite the lapse of time since the 1979 sale.
Main Doctrine
A petition for certiorari under Rule 65 of the Rules of Court is not a remedy for errors of judgment, which are correctible by appeal. It is only available to correct grave abuse of discretion equivalent to lack or excess of jurisdiction. Furthermore, a party who invokes the jurisdiction of a court cannot later challenge that same jurisdiction.