Cabigas v. Limbaco
REITERATIONFacts
1. The Antecedents: The underlying dispute concerns the ownership of two parcels of land. The petitioners, heirs of Nicolas S. Cabigas, claim ownership based on a sale from Salvador Cobarde in 1980. Cobarde had allegedly purchased these lots from Ines Ouano in 1948. However, Ouano had previously sold the same lots to the National Airports Corporation (NAC) in 1952, which registered the titles in its name. After the airport project was abandoned, Ouano's heirs reacquired title and subsequently sold the subdivided lots to various respondents, including Melba Limbaco, Linda Logarta, Ramon Logarta, Henry See, Freddie Go, Benedict Que, AWG Development Corporation, Petrosa Development Corporation, and University of Cebu Banilad, Inc. The petitioners filed a complaint for annulment of titles, alleging that their predecessors-in-interest had validly purchased the properties. 2. Procedural History: The petitioners filed a complaint for annulment of titles with the Regional Trial Court (RTC) of Cebu City. The RTC granted a motion for summary judgment filed by AWG, Petrosa, and UCB, dismissing the petitioners' complaint. The RTC reasoned that the National Airports Corporation was a buyer in good faith, and its registered title cut off prior unregistered transactions, rendering the petitioners' claim invalid under the Torrens system. The petitioners filed an ordinary appeal with the Court of Appeals (CA). The CA, in a resolution dated May 31, 2006, dismissed the appeal concerning AWG, Petrosa, and UCB, stating that the appeal raised only questions of law and should have been filed as a petition for review on certiorari with the Supreme Court. The CA remanded the case for further proceedings regarding other respondents. In a subsequent resolution dated October 4, 2006, the CA clarified that it lacked jurisdiction to entertain the appeal due to the question of law and therefore could not remand the case, as the RTC had already dismissed the complaint in its entirety. 3. The Petition: The petitioners seek a review on certiorari of the CA's resolutions, arguing that the CA committed grave error in dismissing their appeal and asserting that substantial justice and equity warrant a reversal. They contend that a summary judgment is appealable via ordinary appeal to the CA, not exclusively by certiorari to the Supreme Court. The core of their argument is that the CA erred in dismissing their appeal on a technicality, preventing a full review of the merits of their claim to the properties.
Issue(s)
Whether the Court of Appeals committed grave and serious error in dismissing the appeal and in holding that a summary judgment is appealable only through a petition for review on certiorari under Rule 45 to the Supreme Court. Whether the paramount and overriding considerations of substantial justice and equity justify the reversal and setting aside of the questioned resolutions, specifically concerning the propriety of the summary judgment.
Ruling
The Supreme Court affirmed the assailed CA resolutions, denying the petition for lack of merit.
Ratio Decidendi
On the issue of the wrong mode of appeal: The Court reiterated that appeals from RTC decisions in the exercise of original jurisdiction raising questions of fact or mixed questions of fact and law are ordinary appeals to the Court of Appeals under Rule 41. However, appeals raising only questions of law must be filed with the Supreme Court via a petition for review on certiorari under Rule 45. A question of law exists when the issue does not require an examination of the probative value of evidence but concerns the correct application of law and jurisprudence. The RTC's resolution, while seemingly touching on good faith, ultimately applied legal principles regarding the Torrens system and the effect of registration to undisputed facts. The RTC's conclusion that petitioners had no legally recognized interest, based on the registration of title in the National Airports Corporation's name and the lack of alleged bad faith, was a legal determination. Therefore, the appeal to the CA, which raised these legal conclusions, was indeed a question of law, making the CA's dismissal for lack of jurisdiction proper. On the propriety of the summary judgment and considerations of substantial justice: The Court found that a summary judgment was proper. While some respondents initially denied the sale between Ouano and Cobarde, a closer examination revealed that the core issue was not the existence of the sale but the legal effect of subsequent registrations and the good faith of the parties involved. The petitioners' claim was fatally flawed because they failed to allege bad faith on the part of the National Airports Corporation (NAC), the first registrant. Under Article 1544 of the Civil Code, ownership of immovable property goes to the one who first recorded the sale in good faith. Since petitioners did not impute bad faith to NAC, the presumption of good faith prevailed. NAC's registration, therefore, cut off all prior unrecorded transactions, including the alleged sale to Cobarde. Consequently, Cobarde had no valid interest to transfer to the Cabigas spouses, and by extension, the petitioners had no legally enforceable right to the property. The RTC correctly concluded that there was no genuine issue of material fact that necessitated a full trial, as the petitioners' claim was legally untenable based on the undisputed facts and applicable law.
Main Doctrine
An appeal raising only questions of law from a Regional Trial Court's decision in the exercise of its original jurisdiction must be filed with the Supreme Court via a petition for review on certiorari under Rule 45, and not an ordinary appeal with the Court of Appeals. The Court of Appeals correctly dismisses such an appeal for lack of jurisdiction. A summary judgment is proper when there is no genuine issue as to any material fact, and the moving party is entitled to a judgment as a matter of law.