Roman Catholic Archbishop of San Fernando, Pampanga v. Soriano
REITERATIONFacts
1. The Antecedents: The Roman Catholic Archbishop (RCA) of San Fernando, Pampanga, claims ownership of a tract of land in Macabebe, Pampanga, evidenced by Original Certificate of Title (OCT) No. 17629. The RCA filed an ejectment case against individuals it alleged unlawfully occupied the land. These individuals countered that the RCA's title was spurious and that they had acquired the land by acquisitive prescription due to their long-standing possession. 2. Procedural History: The Municipal Circuit Trial Court (MCTC) ruled in favor of the RCA in the ejectment case, ordering the defendants to vacate. The defendants' appeal to the Regional Trial Court (RTC) was dismissed for failure to file an appeal memorandum, and their subsequent petition for certiorari to the Court of Appeals (CA) was also denied. This rendered the MCTC decision final and executory. Separately, some of the defendants filed a case for Quieting of Title and Declaration of Nullity of Title against the RCA, which the RTC denied a motion to dismiss. The RCA's subsequent petition for certiorari to the CA was dismissed, leading to the RCA's petition for review on certiorari before the Supreme Court. 3. The Petition: The Supreme Court is presented with two petitions: G.R. No. 153829, a Petition for Review on Certiorari filed by the RCA assailing the CA's decision upholding the RTC's denial of the motion to dismiss in the quieting of title case, and G.R. No. 160909, a Petition for Injunction filed by Benjamin Guinto, Jr. seeking to enjoin the execution of the MCTC's ejectment order. The RCA argues that the quieting of title case constitutes a collateral attack on its title and violates rules on joinder of actions. Guinto argues that enjoining the execution is necessary to prevent irreparable damage. The Court consolidated the petitions and treated Guinto's petition as a motion for TRO/preliminary injunction in the RCA's case.
Issue(s)
Whether the CA erred in not holding that the RTC committed grave abuse of discretion in denying the motion to dismiss filed by the RCA in the quieting of title case. Whether the civil action for quieting of title and declaration of nullity of title is legally dismissible for violation of the Rules of Court. Whether the civil action constitutes a collateral attack on the RCA's title. Whether the implementation of the writ of execution should be enjoined.
Ruling
The Supreme Court denied the petition in G.R. No. 153829, affirming the CA's decision. The motion for the issuance of a TRO and/or writ of preliminary injunction in G.R. No. 160909 was also denied for lack of merit.
Ratio Decidendi
On the denial of the motion to dismiss and grave abuse of discretion: The Court reiterated the well-entrenched rule that the denial of a motion to dismiss by a trial court cannot generally be questioned through a petition for certiorari under Rule 65, as certiorari is a remedy for errors of jurisdiction, not errors of judgment. The appropriate recourse is to file an answer and raise the objections as affirmative defenses, and then appeal any adverse decision. This rule is applied sparingly, only when there is a clear showing of grave abuse of discretion, meaning the trial court exercised its power arbitrarily or despotically, amounting to an evasion of a positive duty or a virtual refusal to act in contemplation of law. In this case, the CA correctly found no grave abuse of discretion on the part of the RTC in denying the motion to dismiss. The CA clarified that the requirement of legal or equitable title for an action to quiet title to prosper is a matter to be determined after trial on the merits, not a condition precedent to file the action. Similarly, laches is a defense that requires factual determination during trial. On the alleged violation of the rule on joinder of actions: The RCA's contention that the joinder of an action for quieting of title (a special civil action) with an action for declaration of nullity of title (governed by ordinary rules) violates Section 5, Rule 2 of the Rules of Civil Procedure is without merit. Section 6 of Rule 2 explicitly states that misjoinder of causes of action is not a ground for dismissal of an action. Therefore, even if there was a misjoinder, it would not warrant the dismissal of the case. On the issue of collateral attack: The Court agreed with the CA that the action filed by the respondents does not constitute a collateral attack on the RCA's title. An attack on a title is considered direct when its objective is to annul or set aside the judgment pursuant to which the title was decreed, or to enjoin its enforcement. Conversely, an attack is indirect or collateral when, in an action seeking a different relief, the attack on the judgment is made as an incident thereof. In this case, the complaint directly questioned the genuineness and validity of OCT No. 17629, alleging it was spurious, fake, and contained apparent erasures, and that it was misrepresented as a reconstituted title. These allegations clearly constitute a direct attack on the title. On the injunction to enjoin the writ of execution: The petition for injunction was denied for lack of merit. To be entitled to a preliminary injunction, the applicant must show a clear and unmistakable right that is directly threatened and that its invasion would cause material and substantial damage, requiring urgent and paramount necessity for the writ. In this case, the defendants in the ejectment case had no such legal right to protect. The MCTC decision ordering them to vacate had become final and executory, meaning their right to possess the property was already declared inferior to that of the RCA. The possibility of irreparable damage without proof of an actual existing right is not a ground for injunction. Therefore, enjoining the execution of a final and executory judgment would be improper.
Main Doctrine
The denial of a motion to dismiss by a trial court, unless tainted with grave abuse of discretion, cannot be questioned via certiorari; the proper recourse is to file an answer and raise the grounds as affirmative defenses, and if the decision is adverse, to appeal. An action questioning the genuineness of a title is a direct attack, not a collateral attack.