Go Ramos-Yeo v. Spouses Chua
REITERATIONFacts
The Antecedents: This case originated from a complaint for Accion Reinvindicatoria filed by Spouses Richard O. Chua and Polly S. Chua against Century Trading Inc. The Spouses Chua alleged that a relocation survey revealed an overlap between their property and Century's property. Subsequently, further surveys indicated errors in the cadastral maps, suggesting that the Spouses Chua's lot was erroneously placed within Century's lot, and that their properties were actually adjoining. This led to the amendment of the complaint to include owners of adjacent lots, namely Marilyn L. Go Ramos-Yeo, Laurence L. Go, Montgomery L. Go (collectively, the Gos), Multi-Realty Development Corporation (Multi-Realty), and ECI Trading Corporation. Procedural History: The Regional Trial Court (RTC) ordered a re-survey of the properties, which revealed discrepancies in the cadastral maps. The RTC then allowed the amendment of the complaint to implead the adjacent lot owners. Multi-Realty filed a motion to dismiss, arguing lack of jurisdiction, which was denied. The Gos were declared in default. The RTC subsequently issued an Amended Decision identifying the properties based on the survey reports and ordering the payment of survey expenses. The Gos later discovered that Spouses Chua had begun constructing a fence encroaching on their properties, allegedly based on the RTC's Amended Decision. In response, the Gos filed an Amended Petition for Annulment of Judgment with the Court of Appeals (CA), arguing lack of jurisdiction over their persons due to improper service of summons and lack of jurisdiction over the subject matter. The CA denied the petition, affirming the RTC's Amended Decision. Both the Gos and Multi-Realty appealed to the Supreme Court. The Petition: The petitioners, the Gos and Multi-Realty, filed Petitions for Review on Certiorari under Rule 45 of the Rules of Court. They contend that the RTC never acquired jurisdiction over their persons due to improper substituted service of summons. Furthermore, they argue that the RTC lacked jurisdiction over the subject matter because the case effectively sought to amend certificates of title, which is a matter exclusively within the jurisdiction of a land registration court and not an ordinary civil action. They also assert that the Amended Decision is void as it attempts to reopen or review decrees of registration beyond the one-year prescriptive period and impairs the rights of innocent purchasers for value. The petitioners argue that they are not barred by laches because a void judgment cannot become final or be the basis for laches.
Issue(s)
Whether the RTC acquired jurisdiction over the persons of the petitioners (Gos) due to improper substituted service of summons. Whether the RTC had jurisdiction over the subject matter of the action, specifically the amendment of certificates of title. Whether the petitioners (Gos and Multi-Realty) are barred by laches from questioning the Amended Decision of the RTC.
Ruling
The petitions are meritorious. The Supreme Court reversed and set aside the Court of Appeals' Decision and Resolution, annulling all proceedings, decisions, resolutions, orders, and other issuances in Civil Case No. TG-893 and CA-G.R. SP No. 50922. The Register of Deeds of Tagaytay City was ordered to cancel any amendments made to the Transfer Certificates of Title of Gos and Multi-Realty and reinstate the boundaries of their respective titles.
Ratio Decidendi
On the issue of jurisdiction over the person of Gos: The Supreme Court held that the RTC did not acquire jurisdiction over the persons of Gos due to invalid substituted service of summons. Personal service is the preferred mode, and substituted service can only be resorted to if personal service is impossible within a reasonable time, requiring specific efforts to locate the defendant and service upon a person of suitable age and discretion residing with the defendant. The Sheriff's Return in this case lacked specific details on the efforts exerted to serve summons personally and failed to substantiate that the person who received the summons was of suitable age and discretion and resided with the defendants. The Court emphasized that compliance with the rules on service of summons is crucial for due process and jurisdiction, and strict adherence to the requirements for substituted service is mandatory. On the issue of jurisdiction over the subject matter: The Supreme Court ruled that the RTC had no jurisdiction over the subject matter, which was to reopen, review, and amend the transfer certificates of title of Gos and Multi-Realty. The Court found that the Amended Complaint, despite being couched as an Accion Reinvindicatoria, was an indirect and collateral attack on the validity and accuracy of the Torrens titles. The prayer for resurvey, amendment of tie-lines, and issuance of amended titles clearly indicated an intent to modify registered titles. The Court reiterated that the amendment of certificates of title is within the exclusive jurisdiction of a court sitting as a land registration court, as provided under Sections 108 and 32 of Presidential Decree (P.D.) No. 1529. The RTC, acting as an ordinary civil court, could not validly order such amendments, especially since the one-year period to reopen a decree of registration had long lapsed, rendering the titles incontrovertible. On the issue of laches: The Supreme Court held that Gos and Multi-Realty are not barred by laches. The Court explained that a judgment rendered without jurisdiction over the subject matter is void, and no laches can attach to a void judgment. Since the RTC lacked jurisdiction over the subject matter, its Amended Decision was null and void. Consequently, any proceedings or judgments based on this void decision, including the appellate proceedings, are also without force and effect. The Court emphasized that jurisdiction is conferred by law and cannot be acquired or waived by the parties, nor can estoppel apply to confer jurisdiction where none exists.
Main Doctrine
A court does not acquire jurisdiction over the person of a defendant if substituted service of summons is not strictly complied with the prescribed requirements. Furthermore, a regular civil court acting as an ordinary civil court does not have jurisdiction over the subject matter of amending Torrens titles, which falls under the exclusive jurisdiction of a land registration court.