Philippine Woman's Christian Temperance Union v. Yangco Heirs Foundation
REVERSALFacts
The Antecedents: Teodoro R. Yangco (2nd and 3rd Generation Heirs) Foundation, Inc. (TRY Foundation) filed a petition for the issuance of a new title in lieu of Transfer Certificate of Title (TCT) No. 20970 T-22702, alleging that the donated property should revert to the donor's heirs due to the expiration of the donee's (Philippine Woman's Christian Temperance Union, Inc. - PWCTUI) corporate term in 1979. The donation stipulated that the property was for a specific charitable purpose and would revert to the donor, his heirs, and assigns if used for any other purpose. Procedural History: The Regional Trial Court (RTC) ordered the cancellation of PWCTUI's TCT and the issuance of a new title in favor of TRY Foundation. The Court of Appeals (CA) affirmed the RTC decision. The Supreme Court denied PWCTUI's petition for review. Subsequently, PWCTUI filed a petition for certiorari and prohibition, seeking to cease and desist from implementing the lower courts' resolutions and to re-open the case. The Petition: PWCTUI argued that the expiration of its corporate term was not a ground for nullifying the donation, that commercial leasing of portions of the land was for charitable purposes, that TRY Foundation lacked legal standing as heirs, and that the action had prescribed. The Supreme Court, however, focused on the jurisdictional issue.
Issue(s)
Whether the Supreme Court Resolutions dated July 21, 2010 and September 15, 2010 in G.R. No. 190193, which denied PWCTUI's petition for review, bar the present petition for certiorari and prohibition. Whether the RTC, acting as a land registration court, had jurisdiction over TRY Foundation's petition, which was in reality a complaint for revocation of donation. Whether the donation made to PWCTUI was validly revoked due to the expiration of its corporate term.
Ruling
The petition is GRANTED. All proceedings taken, decisions, resolutions, orders, and other issuances in LRC Case No. Q-18126(04), CA-G.R. CV No. 90763, and G.R. No. 190193 are ANNULLED and SET ASIDE. The Register of Deeds of Quezon City is ORDERED to CANCEL any Transfer Certificate of Title issued in the name of Teodoro R. Yangco 2nd and 3rd Generation Heirs Foundation, Inc. and to REINSTATE Transfer Certificate of Title No. 20970 T-22702 in the name of Philippine Woman’s Christian Temperance Union, Inc.
Ratio Decidendi
On the issue of whether the Supreme Court Resolutions dated July 21, 2010 and September 15, 2010 in G.R. No. 190193 bar the present petition: The Court ruled that while the doctrine of immutability of judgment generally applies, it must yield to exceptions, particularly when the judgment is void due to lack of jurisdiction. The previous resolutions dealt with mistakes of judgment, whereas the present petition addresses a fundamental mistake of jurisdiction. The issue of jurisdiction is not lost by waiver or estoppel and can be raised even after a judgment has become final. Therefore, the previous resolutions do not serve as a procedural impediment to the present ruling. On the issue of whether the RTC, acting as a land registration court, had jurisdiction over TRY Foundation's petition: The Court held that the RTC lacked jurisdiction. The petition filed by TRY Foundation, despite being captioned as a petition for issuance of a new title under Section 108 of P.D. No. 1529, was in reality a disguised complaint for revocation of donation. Such an action seeks to recover ownership and possession of property, which is an ordinary civil action outside the ambit of summary land registration proceedings. Section 108 of P.D. No. 1529 is for amendments and alterations of certificates of title and not for resolving controversial issues like the revocation of a donation. The RTC should have dismissed the case or re-docketed it as an ordinary civil action, requiring compliance with stricter jurisdictional requirements such as proper service of summons and payment of docket fees, which were absent in this case. On the issue of whether the donation made to PWCTUI was validly revoked due to the expiration of its corporate term: The Court did not directly rule on the merits of the revocation of donation. Instead, it emphasized that the determination of whether the donation merits revocation and reversion of the property could not be settled through the summary proceedings under Section 108 of P.D. No. 1529. Revocation of donation involves litigious and controversial matters that require an exhaustive examination of factual and legal bases in an ordinary civil proceeding. The RTC's judgment, being void for lack of jurisdiction, could not validly declare the donation annulled or order the cancellation of the title. Therefore, the issue of revocation was never properly adjudicated.
Main Doctrine
A petition for the issuance of a new title under Section 108 of P.D. No. 1529 cannot be used to resolve a disguised complaint for revocation of donation, as such action requires ordinary civil proceedings with stricter jurisdictional requirements, including proper service of summons and payment of docket fees. A judgment rendered without jurisdiction is void and cannot become final, even if affirmed on appeal.