Republic v. Atlas Farms, Incorporated
REITERATIONFacts
The Antecedents: On December 4, 1980, Atlas Farms, Incorporated (Atlas Farms) filed an application for registration and confirmation of title over a parcel of land. On December 28, 1981, the trial court granted the application. Petitioner filed a motion for reconsideration on January 28, 1982. Procedural History: Without resolving the motion for reconsideration, the trial court, on October 18, 1982, received a motion from Atlas Farms to withdraw its application. On October 21, 1982, the trial court granted this motion and issued an order withdrawing the application. Seventeen years later, on August 16, 1999, Atlas Farms filed a motion to set aside the order of withdrawal and to revive the decision granting the application. On August 20, 1999, the trial court set aside its previous order and reinstated the decision. Petitioner filed an omnibus motion assailing the validity of the reinstatement order, which was denied on December 28, 1999. The Petition: The Republic of the Philippines filed a petition for certiorari and prohibition, seeking to annul the order of the respondent court that set aside its previous order granting the withdrawal of the application and reinstated the decision.
Issue(s)
Whether the trial court still has jurisdiction to reverse an order that declared the application for registration of title withdrawn, which order became final seventeen years ago, and to revive the decision granting the application for registration of title. Whether the orders dated August 20 and 26, 1999, reinstating the decision, are valid.
Ruling
The Court GRANTS the petition for review on certiorari, and SETS ASIDE the orders dated August 20 and 26, 1999, and February 16, 1999, of the trial court. The Court orders respondent judge Alicia P. Mariño-Co to recall any decree of registration issued as a consequence of the void decision and orders, and the Land Registration Authority and/or the Register of Deeds of Antipolo City (Rizal) to set aside and nullify all titles, original and transfer issued and arising thereon.
Ratio Decidendi
On the issue of jurisdiction to reverse a final order: The lower court no longer had jurisdiction over the case when it issued the order of August 20, 1999, reversing its previous order dated October 21, 1982, and reviving the decision of December 28, 1981. Close to seventeen (17) years had lapsed after the finality of the order granting the withdrawal. The Court noted that Atlas Farms' pretension of not receiving notice of the order was untrue, as it became aware of subsequent applications for the same land and was informed of the withdrawal order. The standing presumption is that counsel is authorized to represent any cause in which he appears, as per Rule 138 of the 1964 Revised Rules of Court. Consequently, the order declaring the application for registration of title withdrawn could no longer be revoked, and the decision reinstated. The decision had become stale, and any action to enforce or revive it had prescribed under Article 1144 of the Civil Code. A stale decision cannot be the source of the issuance of a decree of registration. Thus, the orders dated August 20 and 26, 1999, reinstating the decision, are void and considered non-existent. A void order cannot give life to a decision that has lost its efficacy and cannot affect, impair, or create rights. Such a void order may be assailed at any time. The rule is basic that the court loses jurisdiction upon the finality of the decision, except to order its execution within its lifetime. A decision becomes final upon the expiration of the period to appeal, which is uniformly fixed at fifteen (15) days from notice to the parties, and no appeal is taken therefrom. What is more, the court may no longer set aside, alter, or modify a final order. In this case, the trial court acted on respondent's motion long after it had lost its jurisdiction over the case. On the validity of the orders reinstating the decision: The orders dated August 20 and 26, 1999, which set aside the order of withdrawal and reinstated the decision of December 28, 1981, are void and considered non-existent. This is because the trial court had already lost jurisdiction over the case due to the finality of the October 21, 1982 order granting the withdrawal of the application. A void order cannot give life to a decision that has lost its efficacy and cannot affect, impair, or create rights. Such a void order may be assailed at any time, either directly or collaterally. The court loses jurisdiction upon the finality of a decision or order, except for the purpose of execution within its lifetime. Since the order of withdrawal had become final and executory, the trial court could no longer validly set it aside or revive the original decision granting the registration of title after a lapse of seventeen years. Therefore, any decree of registration issued as a consequence of these void orders must be recalled, and any titles arising therefrom must be set aside and nullified.
Main Doctrine
A court loses jurisdiction over a case upon the finality of its decision or order, and cannot validly set aside or revoke such final order after a considerable lapse of time, especially when the order sought to be revoked declared the withdrawal of an application for registration of title.