Bilag v. Ay-Ay
REITERATIONFacts
The Antecedents: Respondents filed a Complaint for Quieting of Title against petitioners, alleging that their predecessor-in-interest, Iloc Bilag, sold to them various portions of a 159,496-square meter parcel of land situated in Baguio City. Respondents claimed to have paid for the lands, which were delivered to them in 1976, and that Iloc Bilag caused the removal of the lands from Ancestral Land Claims. They further alleged continuous possession and introduction of improvements. Petitioners, however, refused to honor the sales and asserted adverse rights, threatening dispossession. Procedural History: Petitioners moved to dismiss the complaint on grounds of lack of jurisdiction, prescription/laches/estoppel, and res judicata. The RTC Br. 61 dismissed the case, ruling it had no authority, the deeds of sale did not constitute title, and the case was barred by res judicata due to a prior dismissed case (Civil Case No. 3934-R) involving the same parties and subject matter. The Court of Appeals (CA) set aside the dismissal and remanded the case, holding that res judicata was not applicable as the nature of the actions differed, and that the action to quiet title was imprescriptible given the alleged possession since 1976. The Petition: Petitioners sought review of the CA's decision, arguing that the CA failed to address the issue of jurisdiction, which was a primary ground for dismissal.
Issue(s)
Whether the Court of Appeals erred in setting aside the Regional Trial Court's Order of dismissal on the grounds of lack of jurisdiction, prescription/laches/estoppel, and res judicata, specifically focusing on the issue of jurisdiction. Whether the Regional Trial Court has jurisdiction over an action to quiet title concerning lands within the Baguio Townsite Reservation that are allegedly untitled and unregistered public lands.
Ruling
The petition is granted. The Decision and Resolution of the Court of Appeals are reversed and set aside. Civil Case No. 5881-R is dismissed on the ground of lack of jurisdiction.
Ratio Decidendi
On the Issue of Jurisdiction: The Court held that the RTC Br. 61 correctly recognized its lack of jurisdiction over Civil Case No. 5881-R. The subject lands are part of the Baguio Townsite Reservation and are unregistered and untitled public lands. Presidential Decree No. 1271 declared null and void decrees of registration and certificates of title covering lands within the Baguio Townsite Reservation issued pursuant to Republic Act No. 931, unless certain conditions for validation were met, which were not satisfied in this case. The award to Iloc Bilag by virtue of the reopening of Civil Reservation Case No. 1, GLRO Record 211, is covered by the nullification under PD 1271. Consequently, the subject lands are classified as public domain. The authority to award ownership of untitled and unregistered public lands rests with the Director of Lands, not the RTC. Therefore, the RTC had no power to hear and resolve the respondents' action for quieting of title. Any act performed by a court without jurisdiction is null and void and without any binding legal effect. The Court reiterated that when a court has no jurisdiction over the subject matter, its only power is to dismiss the action. The CA's failure to address this crucial ground of lack of jurisdiction was a reversible error. The Court found no further need to discuss the other grounds relied upon by petitioners, such as res judicata and laches, as the dismissal on jurisdictional grounds rendered those issues moot. The Court held that because the RTC lacked jurisdiction over the subject matter, its only power was to dismiss the action. The authority to award ownership of untitled and unregistered public lands rests with the Director of Lands, not the RTC. Therefore, the RTC had no power to hear and resolve the respondents' action for quieting of title.
Main Doctrine
A Regional Trial Court (RTC) lacks jurisdiction over an action to quiet title concerning lands classified as public domain, particularly those within the Baguio Townsite Reservation, as the authority to award ownership of such lands rests with the Director of Lands.