Oppen, Inc. v. Compas
REITERATIONFacts
The Antecedents: Two parcels of land, previously registered under Philippine Merchant Marine School Inc. (PMMSI) and covered by TCT Nos. S-100612 and S-100613, were levied upon. Manufacturers Building, Inc. (MBI) had its lien annotated on August 22, 1986. Ernesto Oppen, Inc. (EOI) also annotated its lien on August 10, 1987, and subsequently acquired the property through a public auction, leading to the issuance of TCT No. 95712 in its name, cancelling TCT No. S-100612. Meanwhile, an alias writ of execution in the case between PMMSI and MBI led to the sale of the properties covered by TCT Nos. S-100612 and S-100613 to respondent Alberto Compas (Compas) on November 8, 2002. Compas was issued a Final Deed of Sale after PMMSI failed to redeem the properties. Procedural History: On September 28, 2005, Compas filed a petition before the RTC-Las Piñas (LRC Case No. LP-05-0089) for the cancellation of TCT Nos. S-100612 and S-100613 and the issuance of new titles in his name. Upon learning of the cancellation of TCT No. S-100612 and issuance of TCT No. 95712 in EOI's name, Compas filed an Amended Petition. EOI filed two motions to dismiss. The first motion, alleging failure to state a cause of action, was denied by the RTC. The second motion argued that the court with jurisdiction should have been the one where the original registration was filed, citing Section 108 of P.D. No. 1529. The RTC denied this second motion, stating Section 108 was inapplicable and it had jurisdiction under Section 2 of P.D. No. 1529. The RTC also denied EOI's motion for reconsideration. EOI then filed a petition for certiorari with the Court of Appeals (CA), alleging grave abuse of discretion by the RTC. The CA denied EOI's petition, affirming the RTC's jurisdiction. EOI's motion for reconsideration was also denied by the CA. The Petition: EOI filed a petition for review on certiorari with the Supreme Court, seeking to reverse the CA's decision and resolution, arguing that the CA erred in affirming the RTC's denial of its motion to dismiss, specifically on the grounds of failure to state a cause of action and lack of jurisdiction over the subject matter.
Issue(s)
Whether the RTC erred in denying EOI's second motion to dismiss on the ground of lack of jurisdiction over the subject matter and improper venue. Whether the amended petition stated a cause of action.
Ruling
The petition is DENIED. The Court of Appeals did not err in affirming the lower court's decision of denying the motion to dismiss of the amended petition.
Ratio Decidendi
On the issue of jurisdiction and venue: The Court reiterated that jurisdiction is conferred by law. Section 2 of P.D. No. 1529 grants Regional Trial Courts (RTCs) exclusive jurisdiction over applications for original land registration and all petitions filed after original registration. Section 108 of P.D. No. 1529, which EOI relied upon, pertains to amendments and alterations of certificates of title and contemplates summary proceedings for clerical corrections, not controversial issues. The CA correctly found that Section 108 was inapplicable because the present case involved adversarial issues, specifically Compas assailing the title issued to EOI. Therefore, the petition was properly filed with the RTC-Las Piñas. Furthermore, even if Section 108 were applicable, EOI's second motion to dismiss, which raised the issue of improper venue (arguing the case should have been filed with the court of original registration), was correctly denied. This is because EOI had already filed a first motion to dismiss on other grounds, and by failing to raise the issue of improper venue in the first motion, it waived this ground under the Omnibus Motion Rule. The second motion to dismiss, raising improper venue, was therefore barred. On the issue of failure to state a cause of action: While EOI argued that its Torrens title was indefeasible and could not be collaterally attacked, the Court noted that EOI itself filed a motion to dismiss on this ground, indicating a lack of unanimity and the presence of adversarial issues. The Court's affirmation of the RTC's jurisdiction implicitly addresses this, as the RTC was deemed capable of resolving such contentious matters. The core of the dispute revolved around the validity and enforceability of liens and titles, which falls within the purview of the RTC's general jurisdiction over land registration matters, as clarified by Section 2 of P.D. No. 1529.
Main Doctrine
A second motion to dismiss based on improper venue is deemed waived under the Omnibus Motion Rule if the ground of improper venue was not raised in the first motion to dismiss, even if the first motion was based on failure to state a cause of action.