Republic v. Molinyawe
REITERATIONFacts
The Antecedents: Criminal cases for malversation were filed against Florentino Molinyawe. Subsequently, a forfeiture case (Civil Case No. 6379) was filed against Florentino and others, involving several parcels of land registered in the names of Spouses Miranda, Spouses Padilla, and Vivencio Leus. A notice of lis pendens was annotated on the titles. The CFI-Pasig declared the sale of the properties null and void and ordered their forfeiture in favor of the Republic. This decision became final and executory. A writ of execution was issued, but the Republic failed to cancel the titles and transfer them to its name for over thirty years, as Florentino did not turn over the owner's duplicate copies. Procedural History: Florentino was acquitted in the malversation cases. Years later, the heirs of Florentino (respondents) filed a Complaint/Petition (Civil Case No. 10-658) for the cancellation of the lis pendens and quieting of title on the ground of prescription due to the non-execution of the forfeiture decision. The Republic annotated the forfeiture decision on the titles. The Republic also filed a separate action (LRC Case No. M-5469) for the annulment of the owner's duplicate copies of the TCTs, which was decided in favor of the Republic, ordering the cancellation of the duplicates and the issuance of new ones in the Republic's name. These new titles were issued. Subsequently, the respondents filed a Motion to Admit Amended and Supplemental Petition in Civil Case No. 10-658. The RTC-Branch 57 granted this motion, despite the Republic's opposition and motion for reconsideration, which was denied. The Petition: The Republic filed a petition for certiorari with the Court of Appeals (CA), assailing the RTC-Branch 57's orders admitting the amended petition, arguing that the RTC lacked jurisdiction, that the amendment sought to review a final and executory decision of a co-equal court, and that it constituted a collateral attack on the new TCTs. The CA dismissed the Republic's petition, finding no grave abuse of discretion. The Republic then filed a petition for review on certiorari with the Supreme Court.
Issue(s)
Whether the RTC-Branch 57 committed grave abuse of discretion amounting to lack or excess of jurisdiction in admitting the respondents' Amended and Supplemental Petition. Whether the RTC-Branch 57 had jurisdiction over Civil Case No. 10-658, which sought the cancellation of lis pendens and quieting of title. Whether the Amended and Supplemental Petition sought to review or alter a final and executory decision of a co-equal court. Whether the CA exceeded its jurisdiction under Rule 65 by ruling on the contingency of the civil forfeiture case on the criminal case.
Ruling
The petition is granted. The Decision of the Court of Appeals is reversed and set aside. Civil Case No. 10-658 pending before the Regional Trial Court, Branch 57, Makati City is ordered dismissed.
Ratio Decidendi
On the RTC-Branch 57's jurisdiction and grave abuse of discretion: The Supreme Court ruled that the RTC-Branch 57 committed grave abuse of discretion amounting to lack or excess of jurisdiction. The Court found that the RTC violated procedural rules and well-settled rulings by admitting the amended and supplemental petition. The forfeiture case (Civil Case No. 6379) was decided by the CFI-Pasig, which had jurisdiction over the main action involving the subject properties. Consequently, only the CFI-Pasig (or its successor) could order the cancellation of the lis pendens, not the RTC-Branch 57. The RTC-Branch 57's admission of the amended petition was arbitrary and whimsical, as it lacked jurisdiction over the main action. On the jurisdiction of RTC-Branch 57 regarding Civil Case No. 10-658 and the nature of lis pendens: The Court reiterated that a notice of lis pendens places the property under the power and control of the court having jurisdiction over the main case. The power to cancel a notice of lis pendens is merely ancillary to the main action and can only be exercised by the court having jurisdiction over that main action. In this case, the CFI-Pasig had jurisdiction over the forfeiture case, making it the proper court to order the cancellation of the lis pendens, not the RTC-Branch 57. The notice of lis pendens had already served its purpose and become functus officio upon the finality of the decision in the forfeiture case. The Court also held that the RTC-Branch 57 should have dismissed the respondents' motion to admit the amended and supplemental petition motu proprio for lack of jurisdiction, pursuant to Section 1, Rule 9 of the Rules of Court. On the finality of judgments and the power to alter them: The Court emphasized that the decision in the forfeiture case (Civil Case No. 6379) had become final and executory in 1974. Furthermore, the decision in LRC Case No. M-5469, which declared the owner's duplicate copies of the TCTs null and void and ordered the issuance of new ones in the Republic's name, had also attained finality. The RTC-Branch 57 could not alter or modify these final and executory decisions of co-equal courts through the admission of an amended petition. Such an act would defeat the purpose of amendments and constitute grave abuse of discretion. On the CA's observation regarding the acquittal in the criminal case: The Court clarified that the CA's remark about Florentino's acquittal in the malversation case rendering the forfeiture ineffective was an obiter dictum and lacked procedural basis. The forfeiture case under R.A. No. 1379 is a civil forfeiture proceeding, independent of any criminal case. There is no law mandating the automatic dismissal of a forfeiture case upon acquittal in a criminal case for malversation. The cases are separate and distinct.
Main Doctrine
A court that does not have jurisdiction over the main action involving a property cannot validly admit an amended petition seeking to cancel a notice of lis pendens or to quiet title over the same property, as the power to cancel a notice of lis pendens is merely ancillary to the main action and can only be exercised by the court having jurisdiction over the main case. Furthermore, a court cannot alter or modify a final and executory judgment of a co-equal court.