Baricuatro v. Caballero
REITERATIONFacts
The Antecedents: Respondents filed a complaint for Quieting of Title, Cancellation of Free Patents/OCT, and Damages against petitioners concerning two parcels of land in Naga, Metro Cebu. The initial complaint was filed with the Regional Trial Court (RTC), Branch 16, but was withdrawn by the respondents. Procedural History: Following the withdrawal from the RTC, respondents refiled the complaint with the Municipal Trial Court (MTC), which dismissed it for lack of jurisdiction. Respondents then filed a Motion to Reinstate the case with RTC Branch 16, which was denied. Subsequently, respondents re-filed the complaint with RTC Branch 13, which denied petitioners' motion to dismiss. Petitioners then elevated the matter to the Court of Appeals (CA) via a Petition for Certiorari, alleging that the RTC had lost jurisdiction. The CA denied the petition, finding that the RTC had jurisdiction and that respondents were not guilty of forum shopping. The CA subsequently denied petitioners' motion for reconsideration. The Petition: Petitioners seek a reversal of the CA's decision and resolution through a Petition for Review on Certiorari under Rule 45 of the Rules of Court. They argue that the denial of their Motion to Reinstate Case by RTC Branch 16 became final and executory, divesting the RTC of jurisdiction. Petitioners contend that the RTC Branch 13 could not have acquired jurisdiction and that the CA erred in its ruling.
Issue(s)
Whether the Order of Dismissal of the Complaint by RTC Branch 16, Cebu City, became final and executory, thereby causing loss of jurisdiction on the case on the part of the Regional Trial Court, Cebu City. Whether the denial of the Motion to Reinstate Case by RTC Branch 16 was a final disposition of the case, barring re-filing.
Ruling
The petition is denied for lack of merit. The Decision of the Court of Appeals is affirmed.
Ratio Decidendi
On the issue of whether the Order of Dismissal of the Complaint by RTC Branch 16 became final and executory, thereby causing loss of jurisdiction: The Court held that the principle of res judicata does not apply in this case because the Order of RTC Branch 16 denying respondents' Motion to Reinstate Case was not a judgment on the merits. A judgment on the merits determines the rights and liabilities of the parties based on the ultimate facts disclosed by the pleadings or issues presented for trial, which was not the case here. The Order of Branch 16 merely addressed the procedural aspect of re-filing and the jurisdiction of the MTC, without passing upon the substantive issues of quieting of title, cancellation of free patents, or damages. Therefore, the denial of the motion to reinstate did not bar the re-filing of the complaint, and the RTC did not lose jurisdiction over the case. The Court reiterated that jurisdiction attaches to the court, not to the judge, and the act of Branch 13 assuming jurisdiction was corrective of any impropriety committed by Branch 16. On the issue of whether the denial of the Motion to Reinstate Case was a final disposition of the case, barring re-filing: The Court found that the denial of the motion to reinstate was not a judgment on the merits. The respondents' act of seeking to reinstate the complaint demonstrated their compliance with the MTC's order of dismissal for lack of jurisdiction and their intent not to appeal that specific order. Consequently, RTC Branch 16 could not have insisted that respondents should have appealed the MTC order. Since the order of RTC Branch 16 was not a judgment on the merits, the doctrine of res judicata was inapplicable, and the re-filing of the complaint with the RTC was not barred. The CA correctly pointed out that the actions of the two RTC branches, even if seemingly opposed, did not affect the court's jurisdiction over the case, and the assumption of jurisdiction by Branch 13 served to correct any error made by Branch 16.
Main Doctrine
The denial of a motion to reinstate a case is not a judgment on the merits, and therefore, the principle of res judicata does not apply, allowing for the re-filing of the complaint. Furthermore, the assumption of jurisdiction by one branch of the Regional Trial Court can be corrective of errors made by another branch, and jurisdiction attaches to the court, not the judge.