Coombs v. Castañeda
REITERATIONFacts
1. The Antecedents: The underlying dispute concerns a property in Muntinlupa City covered by Transfer Certificate of Title (TCT) No. 6715. Petitioner Mercedita C. Coombs claims ownership of this property. She discovered in March 2005 that the property was no longer listed under her name, having been cancelled and replaced by TCT No. 14115 issued to respondent Virgilio Veloso Santos. Santos subsequently sold the property to respondents Pancho and Edith Leviste, who then mortgaged it to respondent BPI Family Savings Bank. Coombs asserts she never authorized Victoria C. Castañeda to file a petition for the issuance of a second owner's duplicate copy of TCT No. 6715, nor to sell the property. 2. Procedural History: Coombs filed a petition for annulment of judgment before the Court of Appeals (CA) to declare void a Decision dated August 26, 2004, by the Regional Trial Court (RTC) of Muntinlupa City in LRC Case No. 04-035. This RTC Decision declared the lost owner's duplicate copy of TCT No. 6715 null and void and ordered the issuance of a new one. The CA dismissed Coombs' petition for annulment of judgment in a Resolution dated April 30, 2009, citing failure to comply with Rule 47 of the Revised Rules of Court, specifically the lack of allegation that ordinary remedies were unavailable and insufficient substance. Coombs' motion for reconsideration was denied by the CA in a Resolution dated May 25, 2010, which reiterated the dismissal, stating the RTC had jurisdiction and that Coombs failed to append supporting documents. 3. The Petition: This case is before the Supreme Court on a petition for review on certiorari under Rule 45 of the Rules of Court. Coombs argues that the CA erred in dismissing her petition for annulment of judgment. She contends that the RTC lacked jurisdiction over LRC Case No. 04-035 because the owner's duplicate copy of TCT No. 6715 was never lost and remained in her possession, making the RTC's decision void. She also argues that when a petition for annulment is based on lack of jurisdiction, the petitioner need not allege the unavailability of ordinary remedies, and that she did append supporting documents, including the TCT itself and the RTC Decision, which sufficiently supported her cause of action. She seeks to have the CA's resolutions reversed and to have her petition for annulment of judgment given due course.
Issue(s)
Whether the Court of Appeals erred in dismissing outright petitioner Coombs' petition for annulment of judgment. Whether the RTC acquired jurisdiction over LRC Case No. 04-035.
Ruling
The petition is meritorious. The Court of Appeals erred when it dismissed outright the petition for annulment of judgment. The Resolutions dated April 30, 2009 and May 25, 2010 of the Court of Appeals in CA-G.R. SP No. 107949 are SET ASIDE. The Court of Appeals is directed to REINSTATE the Petition for Annulment of Judgment in CA-G.R. SP No. 107949 and to proceed hearing the same with dispatch.
Ratio Decidendi
On the issue of whether the Court of Appeals erred in dismissing outright petitioner Coombs' petition for annulment of judgment: The Supreme Court ruled that the Court of Appeals erred in dismissing the petition outright. The petition was clearly grounded on lack of jurisdiction, not extrinsic fraud, as alleged by the CA. Petitioner Coombs averred that the owner's duplicate copy of TCT No. 6715 was not lost but was in her possession, meaning the RTC never acquired jurisdiction to entertain the petition for the issuance of a new duplicate certificate. This allegation, if true, would render the RTC Decision void. The Court found that these allegations made out a prima facie case for annulment of judgment, warranting the CA's favorable consideration. The CA's dismissal based on technical grounds, such as failure to allege prior availment of ordinary remedies and failure to append supporting documents, was also erroneous. On the issue of whether the RTC acquired jurisdiction over LRC Case No. 04-035: The Supreme Court held that the RTC did not acquire jurisdiction over the subject matter of LRC Case No. 04-035. Jurisdiction over the nature of the action or subject matter is conferred by law. While Section 10 of Republic Act No. 26 vests the RTC with jurisdiction over the judicial reconstitution of a lost or destroyed owner's duplicate of a title, this jurisdiction is contingent upon the fact of loss. The Court has consistently held that the RTC has no jurisdiction when the certificate sought to be reconstituted was never lost or destroyed but is in fact in the possession of another person. Therefore, the fact of loss of the duplicate certificate is jurisdictional. Petitioner Coombs' allegation that the owner's duplicate copy of TCT No. 6715 was never lost and was always in her possession gave rise to a prima facie case of the RTC's lack of jurisdiction. This is precisely the situation a petition for annulment of judgment aims to remedy. Furthermore, the Court clarified that when a petition for annulment of judgment is grounded on lack of jurisdiction, the petitioner need not allege that ordinary remedies were unavailable through no fault of her own, as a judgment rendered without jurisdiction is fundamentally void and can be questioned at any time, unless laches has set in. The Court also found that Coombs did attach supporting documents, namely the owner's duplicate copy of TCT No. 6715 and the RTC Decision, which sufficiently supported her cause of action.
Main Doctrine
A petition for annulment of judgment grounded on lack of jurisdiction does not require the petitioner to allege prior availment of ordinary remedies, as a judgment rendered without jurisdiction is void and can be questioned at any time, barring laches. The fact of loss of the owner's duplicate copy of a title is jurisdictional in reconstitution cases.