Privatization & Management Office v. Quesada
REITERATIONFacts
1. The Antecedents: The respondents, the Quesada heirs, are the registered owners of a parcel of land in Quezon City under Transfer Certificate of Title (TCT) No. 27090, the original copy of which was destroyed in a 1998 fire at the Quezon City Hall. The owner's duplicate copy of TCT No. 27090 is currently held by the Privatization and Management Office (PMO), having been delivered in 1983 by the Quesadas' predecessors-in-interest to Golden Country Farms, Inc. (now under PMO's purview) to secure an obligation under a Growership Agreement. The Quesadas assert this obligation has been extinguished by prescription and declared unenforceable by a 1999 court decision, and they require the surrender of the owner's duplicate title to facilitate the transfer of ownership to their names, which they have been unable to obtain from the PMO despite repeated demands. 2. Procedural History: The Quesadas filed a petition with the Regional Trial Court (RTC) of Quezon City, Branch 105, seeking to compel the PMO to surrender the owner's duplicate of TCT No. 27090 under Section 107 of Presidential Decree (P.D.) No. 1529. The PMO moved to dismiss the petition, citing lack of cause of action, lack of jurisdiction due to the contentious nature of the claim, and res judicata; the RTC initially denied the motion and converted the case into an ordinary civil action, but upon the PMO's motion for reconsideration, it reconsidered and dismissed the petition for lack of jurisdiction. The Quesadas then filed a petition for certiorari with the Court of Appeals (CA), arguing grave abuse of discretion by the RTC, which the CA granted, setting aside the RTC's dismissal orders and denying the PMO's motion to dismiss, with the PMO's subsequent motion for reconsideration also being denied by the CA. 3. The Petition: This case is a Petition for Review on Certiorari under Rule 45 of the Rules of Court, filed by the Privatization and Management Office (PMO) assailing the Decision of the Court of Appeals (CA) dated June 29, 2015, and its Resolution dated May 2, 2016. The PMO contends that the CA erred in giving due course to the Quesadas' petition for certiorari, arguing that it was not the proper remedy to question an order of dismissal, which is a final order normally appealable. Furthermore, the PMO argues that the CA erred in ruling that the RTC, as a land registration court, could take cognizance of the petition to surrender the duplicate title under Section 107 of P.D. No. 1529, asserting that the petition failed to state a cause of action and that the issues involved were contentious and beyond the summary jurisdiction of a land registration court.
Issue(s)
Whether the Court of Appeals erred in giving due course to the petition for certiorari when it is not the proper remedy to seek a review from an order of dismissal. Whether the Court of Appeals erred in ruling that the Regional Trial Court can take cognizance of the petition to surrender the duplicate copy of TCT No. 27090 pursuant to Section 107 of P.D. No. 1529.
Ruling
The Supreme Court denied the petition for lack of merit, affirming the Court of Appeals' Decision and Resolution. The petition to surrender TCT No. 27090 was reinstated, and the Regional Trial Court was directed to conduct a full-blown hearing with dispatch.
Ratio Decidendi
On the first issue (Propriety of Certiorari): The Court acknowledged that the RTC's Order dismissing the petition for lack of jurisdiction was a final order normally subject to appeal. However, it found that the CA did not commit reversible error in giving due course to the petition for certiorari and treating it as an ordinary appeal. The Court cited several instances where it has treated a petition for certiorari as a petition for review on certiorari, particularly when the certiorari petition was filed within the reglementary period for appeal, errors of judgment were averred, and there was sufficient reason to justify the relaxation of the rules in the interest of substantial justice. The Court emphasized that while certiorari is an extraordinary remedy, it may be resorted to despite the availability of an appeal when the exigencies of the case require it, such as when ordinary methods of appeal may not be adequate or when the broader interests of justice so require. In this case, the petition for certiorari was filed within the reglementary period for appeal, and the broader interests of justice justified the relaxation of the rules. On the second issue (Jurisdiction of RTC): The Court ruled that the RTC, as a land registration court, has jurisdiction over the petition to surrender the duplicate copy of TCT No. 27090. Section 107 of P.D. No. 1529 contemplates two situations for such a petition: (1) when a new certificate of title is necessary due to an involuntary instrument divesting title against the owner's consent, and (2) when a voluntary instrument cannot be registered due to the holder's refusal to surrender the duplicate title. The Court found that the Quesadas' petition sufficiently alleged a cause of action under the second situation, as they sought the surrender of the duplicate title to register a voluntary instrument (Deed of Donation) which could not be registered due to PMO's refusal. Furthermore, Section 2 of P.D. No. 1529 confers broad jurisdiction upon the RTC, as a land registration court, to hear and determine all questions arising from petitions filed after original registration, including contentious and substantial issues. The distinction between the general jurisdiction of the RTC and its limited jurisdiction as a cadastral court was eliminated by P.D. No. 1529, empowering RTCs to resolve even controversial cases. Therefore, the RTC, being a court of general jurisdiction, could take cognizance of the petition, thresh out the issues in a full-blown hearing, receive evidence, and resolve the conflicting claims, making the dismissal for lack of jurisdiction unwarranted.
Main Doctrine
A petition for certiorari may be treated as a petition for review on certiorari if filed within the reglementary period for appeal, averring errors of judgment, and with sufficient reason to justify the relaxation of the rules, especially when the broader interests of justice so require. Furthermore, Regional Trial Courts, acting as land registration courts, possess broad jurisdiction under Section 2 of P.D. No. 1529 to hear and determine all questions arising from petitions filed after original registration, including contentious and substantial issues, thereby avoiding multiplicity of suits.