Mandaue Realty v. Bangko Sentral
REITERATIONFacts
The Antecedents: Bangko Sentral ng Pilipinas (BSP) filed a Complaint for Annulment of Title/Reconveyance/Reinstatement of Title against Mandaue Realty & Resources Corporation (MARRECO). BSP sought to cancel Transfer Certificate of Title (TCT) No. 54456 registered in MARRECO's name and reinstate TCT No. 46781 registered in BSP's name, covering the same property. BSP argued that an Order dated January 19, 2004, in a prior case (Civil Case No. MAN-3902), which nullified BSP's title and restored it to MARRECO, was null and void. Procedural History: MARRECO filed a Motion to Dismiss, asserting that the Regional Trial Court (RTC) Branch 56 lacked jurisdiction as the complaint sought to annul a judgment of a co-equal court, that the issue was barred by res judicata, and that BSP engaged in forum shopping. The RTC Branch 56 dismissed BSP's complaint, ruling it had no jurisdiction. BSP appealed this dismissal to the Court of Appeals (CA) via a Notice of Appeal. MARRECO filed a Motion to Dismiss Appeal, arguing the issues were pure questions of law, thus the CA lacked jurisdiction. The CA denied MARRECO's motion, finding the issues involved mixed questions of fact and law. MARRECO moved for reconsideration, which the CA also denied. MARRECO then filed a Petition for Certiorari and Mandamus with the Supreme Court, assailing the CA's Resolutions. The Petition: MARRECO argued that the CA acted with grave abuse of discretion in denying its Motion to Dismiss Appeal and assuming jurisdiction, as the issues in BSP's appeal were pure questions of law, which should have been elevated directly to the Supreme Court via a Rule 45 petition.
Issue(s)
Whether the Court of Appeals acted with grave abuse of discretion amounting to lack or excess of jurisdiction when it denied MARRECO's Motion to Dismiss Appeal and assumed jurisdiction over BSP's appeal. Whether the issues raised in BSP's appeal to the Court of Appeals involved pure questions of law or mixed questions of fact and law.
Ruling
The Supreme Court dismissed the petition for Certiorari and Mandamus, affirming the Resolutions of the Court of Appeals dated July 25, 2008, and October 21, 2008. The Court directed the records to be remanded to the Court of Appeals for further proceedings.
Ratio Decidendi
On the issue of whether the Court of Appeals acted with grave abuse of discretion: The Court held that a petition for certiorari will only lie in cases of grave abuse of discretion, which must be patent and gross, amounting to an evasion of a positive duty or a virtual refusal to perform a duty enjoined by law. Mandamus is a writ requiring the performance of a specific duty. In this case, the CA did not commit grave abuse of discretion in denying MARRECO's Motion to Dismiss Appeal and assuming jurisdiction over BSP's appeal. The determination of whether the issues raised were pure questions of law or mixed questions of fact and law was within the CA's purview. The Court found that the CA correctly assessed the nature of the issues presented in BSP's appeal. On the nature of the issues raised in BSP's appeal: The Court reiterated the distinction between appeals involving questions of law and those involving questions of fact or mixed questions of fact and law, as provided in Section 2, Rule 41 of the Rules of Court. An appeal involving pure questions of law should be filed with the Supreme Court via a petition for review on certiorari under Rule 45, while an appeal involving questions of fact or mixed questions of fact and law should be filed with the Court of Appeals via an ordinary appeal under Rule 41. The Court clarified that a question of law arises when there is doubt as to the applicable law, while a question of fact arises when there is doubt as to the truth or falsehood of facts. The test is whether the appellate court can resolve the issue without reviewing or evaluating evidence. The Court found that BSP's appeal raised not only questions of law but also questions of fact. Specifically, BSP's allegations regarding the antecedent facts leading to the cancellation of TCT No. 46781 and its status as a mortgagee-in-good-faith required a calibration of evidence. The CA correctly noted that to determine if the RTC's assumption of jurisdiction would intrude upon a co-equal court's domain, the factual circumstances surrounding the cancellation of BSP's title needed examination. Therefore, the appeal properly involved mixed questions of fact and law, making the CA's assumption of jurisdiction under Rule 41 correct.
Main Doctrine
The Court of Appeals may entertain an appeal filed under Rule 41 when the issues raised involve mixed questions of fact and law. A petition for certiorari under Rule 45 is proper only when the issues involve pure questions of law.