Malabanan v. Republic
REITERATIONFacts
1. The Antecedents: The Republic of the Philippines initiated a civil action against Angelo B. Malabanan, Pablo B. Malabanan (petitioner), and Greenthumb Realty and Development Corporation to revert land titles derived from Transfer Certificate of Title (TCT) No. T-24268. The Republic alleged that TCT No. T-24268 originated from Original Certificate of Title (OCT) No. 0-17421, purportedly issued pursuant to Decree No. 589383 in L.R.A. Record No. 50573. However, the Land Registration Authority could not locate any record of the judgment for this decree. The Republic contended that the land covered by TCT No. T-24268 was situated within an unclassified public forest, rendering it part of the public domain and thus not subject to private disposition or registration. 2. Procedural History: The petitioner moved to dismiss the action, arguing that the Regional Trial Court (RTC) lacked jurisdiction because the suit sought to annul a judgment and decree, which fell under the exclusive jurisdiction of the Court of Appeals (CA). The RTC initially granted the motion to dismiss on December 11, 1998, citing its lack of jurisdiction and the need to annul a judgment. The Republic appealed this dismissal. The RTC denied due course to the appeal, prompting the Republic to file a petition for certiorari with the CA. The CA, in a ruling on February 29, 2000, ordered the RTC to give due course to the appeal. Subsequently, on May 27, 2011, the CA reversed the RTC's dismissal order, remanding the case to the RTC for further proceedings, including requiring responsive pleadings and proceeding with the trial on the merits. The CA denied the petitioner's motion for reconsideration on May 4, 2012. 3. The Petition: The petitioner seeks review of the CA's decision, arguing that the CA erred in setting aside the RTC's dismissal order and in directing the RTC to proceed with the trial. The petitioner maintains that the action to annul OCT No. 0-17421 and its derivative titles inherently involves the annulment of a final judgment from the Land Registration Court. Therefore, according to the petitioner, the Republic should have filed its complaint for annulment of judgment with the CA, pursuant to Rule 47 of the Rules of Court. The Republic counters that it is not seeking to annul an existing judgment, but rather asserting that no such judgment was ever rendered, and that the action for reversion and cancellation of title falls within the RTC's exclusive jurisdiction.
Issue(s)
Whether the Regional Trial Court (RTC) has jurisdiction over an action for reversion of land and cancellation of title when the State alleges that the land is part of the unclassified public forest and that no judgment authorizing the issuance of the title exists. Whether the action filed by the Republic constitutes an annulment of judgment, which falls under the exclusive jurisdiction of the Court of Appeals (CA).
Ruling
The Supreme Court denied the petition for review on certiorari, affirmed the decision of the Court of Appeals, and ordered the petitioner to pay the costs of suit.
Ratio Decidendi
On the jurisdiction of the RTC over an action for reversion and cancellation of title: The Court held that the jurisdiction of a court over the subject matter is determined by the allegations in the complaint, the law in force at the time of filing, and the character of the relief sought. The complaint alleged that the subject property was within the unclassified public forest of Batangas, rendering it inalienable. Under Section 101 of Commonwealth Act No. 141 (Public Land Act), actions for reversion to the Government of lands of the public domain must be instituted by the Solicitor General in the proper courts. The Court emphasized that an action for reversion, where the ultimate relief sought is to revert the land to the government pursuant to the Regalian Doctrine, is within the exclusive jurisdiction of the RTC. The Court further noted that the allegations in the motion to dismiss required presentation of evidence and determination of facts, which are best resolved in a trial on the merits, not in a motion to dismiss. Therefore, the RTC should have assumed jurisdiction. On whether the action constitutes an annulment of judgment: The Court clarified that the Republic's complaint was not seeking the annulment of a judgment from LRC Record No. 50573, but rather alleged that no such judgment existed. The complaint sought the cancellation of OCT No. 0-17421 and the reversion of the land on the grounds that no decision authorized its issuance and that the land was within the unclassified public forest. This is distinct from an action for annulment of judgment. The Court distinguished this case from those where the Republic sought to annul existing judgments of the Land Registration Court. In reversion suits, the attack is directed against the title itself, not against the judgment ordering its issuance, especially when it is alleged that no judgment was rendered at all. Therefore, Rule 47 of the Rules of Court on annulment of judgment was not applicable.
Main Doctrine
An action for reversion of land and cancellation of title, where the State alleges that the land is part of the unclassified public forest and thus inalienable, is an original action within the exclusive jurisdiction of the Regional Trial Court (RTC), and is distinct from an action for annulment of judgment which falls under the exclusive jurisdiction of the Court of Appeals (CA).