Maslag v. Monzon
REITERATIONFacts
The Antecedents: In 1998, petitioner Darma Maslag filed a complaint for reconveyance of real property and declaration of nullity of an original certificate of title against respondents Elizabeth Monzon, William Geston, and the Registry of Deeds of La Trinidad, Benguet. The case originated before the Municipal Trial Court (MTC) of La Trinidad, Benguet. After trial, the MTC found respondent Monzon guilty of fraud in obtaining the title and ordered her to reconvey the property to petitioner, along with damages and costs. Procedural History: Respondents appealed the MTC decision to the Regional Trial Court (RTC) of La Trinidad, Benguet. The RTC, in an October 22, 2003 Order, declared the MTC without jurisdiction over the case but decided to take cognizance of it under Section 8, Rule 40 of the Rules of Court. Subsequently, on May 4, 2004, a different RTC judge reversed the MTC decision, ordering petitioner to turn over possession of the land to Monzon and remanding the case for determination of petitioner's rights as a builder in good faith. Petitioner filed an ordinary appeal to the Court of Appeals (CA) from this RTC resolution. The Petition: The Court of Appeals dismissed petitioner's ordinary appeal, ruling that because the RTC acted in its appellate capacity when it issued the May 4, 2004 resolution, the proper remedy was a Petition for Review under Rule 42, not an ordinary appeal under Rule 41. Petitioner's motion for reconsideration was denied. The present Petition for Review on Certiorari seeks to have the CA's dismissal of the appeal reversed, arguing that the RTC should have exercised original jurisdiction and that the CA erred in dismissing the appeal based on an improper mode of remedy.
Issue(s)
Whether the Court of Appeals (CA) erred in dismissing petitioner's ordinary appeal; and whether the Regional Trial Court (RTC) exercised its original or appellate jurisdiction when it issued its May 4, 2004 Resolution. What is the proper mode of appeal from an RTC decision rendered under Section 8, Rule 40 of the Rules of Court. On the effect of the RTC's October 22, 2003 Order declaring the MTC without jurisdiction; and the petitioner's argument regarding RTC's original jurisdiction.
Ruling
The Supreme Court denied the Petition for Review for lack of merit and affirmed the Resolutions of the Court of Appeals. The Court held that the CA correctly dismissed petitioner's ordinary appeal because the RTC, in rendering its May 4, 2004 Resolution, acted in its appellate jurisdiction. Therefore, the proper mode of appeal to the CA should have been a Petition for Review under Rule 42, not an ordinary appeal under Rule 41.
Ratio Decidendi
On the propriety of the appeal to the Court of Appeals and the jurisdiction exercised by the RTC: The Court reiterated that the mode of appeal from an RTC decision depends on the jurisdiction exercised by the RTC. An ordinary appeal under Rule 41 is for cases where the RTC exercises its original jurisdiction, while a petition for review under Rule 42 is for cases where the RTC acts in its appellate capacity. In this case, the RTC's May 4, 2004 Resolution reversed a Municipal Trial Court (MTC) judgment, clearly indicating that the RTC was acting in its appellate jurisdiction. Therefore, the CA correctly dismissed the petitioner's ordinary appeal as it was an improper remedy. The Court clarified that while the RTC, in its October 22, 2003 Order, declared the MTC without jurisdiction and stated it would decide the case under Section 8, Rule 40, the subsequent May 4, 2004 Resolution by a different RTC judge explicitly treated the case as an appeal from the MTC judgment. The dispositive portion of this resolution reversed the MTC's findings and remanded residual issues for trial with the MTC. This action demonstrates that the RTC was exercising its appellate jurisdiction. On the proper mode of appeal: Given that the RTC exercised its appellate jurisdiction when it issued the May 4, 2004 Resolution, the proper mode of appeal to the Court of Appeals was a Petition for Review under Rule 42, not an ordinary appeal under Rule 41. Section 2, Rule 50 of the Rules of Court explicitly states that an appeal under Rule 41 taken to the Court of Appeals raising only questions of law, or an appeal by notice of appeal instead of by petition for review from an appellate judgment of an RTC, shall be dismissed. An appeal erroneously taken shall be dismissed outright. On the effect of the RTC's October 22, 2003 Order and the petitioner's argument regarding RTC's original jurisdiction: The Court emphasized that jurisdiction is conferred by law and cannot be determined or set aside by the courts or parties themselves. The RTC's October 22, 2003 Order, which declared the MTC without jurisdiction and purported to allow the RTC to take cognizance of the case under its original jurisdiction, was a "jurisdictional faux pas." Since the assessed value of the property (₱12,400.00) fell within the MTC's exclusive original jurisdiction for cases involving title to real property, the RTC should not have declared the MTC without jurisdiction. The RTC's subsequent May 4, 2004 Resolution, which was an appeal from the MTC, was thus rendered in the exercise of its appellate jurisdiction, despite the earlier erroneous order. The petitioner argued that the RTC should have exercised its original jurisdiction because it had previously declared the MTC without jurisdiction. The Court found this argument without merit. It reiterated that only statutes can confer jurisdiction, and court issuances cannot usurp it. An order issued by a court declaring it has original jurisdiction when the law does not grant it cannot be given effect. The determinative factor for the mode of appeal is the jurisdiction actually exercised by the RTC, not what it should have exercised.
Main Doctrine
The mode of appeal from a Regional Trial Court (RTC) decision or resolution is determined by the nature of the jurisdiction exercised by the RTC in rendering that decision or resolution, not by what jurisdiction the RTC should have exercised. An ordinary appeal under Rule 41 is proper when the RTC exercises its original jurisdiction, while a petition for review under Rule 42 is the correct remedy when the RTC acts in its appellate capacity.