Golez v. Heirs of Bertuldo
REITERATIONFacts
The Antecedents: This case concerns a dispute over Lot No. 1025. In 1976, Spouses Rolando and Susie Golez (petitioners) purchased Lot No. 1024 from Benito Bertuldo. However, petitioners constructed their house on the adjacent Lot No. 1025, which was claimed by Domingo Bertuldo, father of the respondents. After Domingo's death, a relocation survey confirmed petitioners' house was on Lot No. 1025. Petitioners then claimed an Amended Deed of Absolute Sale transferred their purchase from Lot No. 1024 to Lot No. 1025. This led to a Complaint for Quieting of Title filed by petitioners, which was dismissed by the Regional Trial Court (RTC) and affirmed by the Court of Appeals (CA) and the Supreme Court (SC) in G.R. No. 178990, establishing that petitioners purchased Lot No. 1024 and not Lot No. 1025. Procedural History: Following the dismissal of their quieting of title case, respondents applied for a free patent over Lot No. 1025 with the Provincial Environment and Natural Resources Office (PENRO). Petitioners opposed this with their own counter-application, failing to disclose the adverse SC ruling. The PENRO rejected both applications, deeming Lot No. 1025 private land. Petitioners appealed to the Department of Environment and Natural Resources (DENR), docketed as DENR Case No. 8887. Meanwhile, respondents filed an unlawful detainer case, which was eventually dismissed by the SC in G.R. No. 201289 on the grounds of prescription, suggesting an accion publiciana was the proper remedy. The DENR, in its Decision dated April 28, 2011, partially granted petitioners' appeal, ordering a segregation survey and directing both parties to file public land applications. However, in a subsequent Resolution dated December 2, 2011, the DENR granted petitioners' motion for reconsideration, declared Lot No. 1025 as public land, and gave petitioners preferential right over the entire lot. Respondents appealed this Resolution to the Office of the President, but their appeal was not perfected. Consequently, the DENR issued an Order dated July 10, 2012, declaring its December 2, 2011 Resolution final and executory. The Petition: Respondents filed a Petition for Certiorari with the Court of Appeals (CA), assailing the DENR's Order of Finality and Execution. The CA, in its Decision dated July 20, 2016, declared the DENR's Decision and Resolution void, finding that the DENR gravely abused its discretion by disregarding previous rulings that established respondents' ownership of Lot No. 1025. The CA also found petitioners guilty of forum shopping. The CA denied petitioners' motion for reconsideration in a Resolution dated January 20, 2017. Petitioners now seek review of the CA's decision through a Petition for Review on Certiorari under Rule 45 of the Rules of Court, arguing that the CA erred in its findings and that the DENR acted within its jurisdiction.
Issue(s)
Whether or not the filing of the Petition for Certiorari by the respondents before the Court of Appeals was proper. Whether or not the DENR has acted with grave abuse of discretion when it declared the preferential right of the petitioners over the subject lot. Whether or not the dismissal of a case for quieting of title for "lack of merit" constitutes a bar in the filing of an application for issuance of free patent with the PENRO; and whether the petitioners were guilty of forum shopping.
Ruling
The Supreme Court denied the petition and affirmed the Decision and Resolution of the Court of Appeals. The Court held that the DENR gravely abused its discretion in disregarding the prior final and executory decisions of the CA and the Supreme Court which recognized respondents' ownership of Lot No. 1025. Consequently, the DENR's Decision, Resolution, and Order were declared void. The CA's dismissal of petitioners' application for free patent due to forum shopping was also upheld.
Ratio Decidendi
On the propriety of the Petition for Certiorari: The Court found that the petition for certiorari filed by respondents before the CA was proper because the DENR acted with grave abuse of discretion, which falls under the exceptions to the rule that certiorari cannot be a substitute for a lost appeal. The DENR's disregard of prior final and executory decisions recognizing respondents' ownership of Lot No. 1025 was deemed a capricious, whimsical, arbitrary, or despotic exercise of jurisdiction equivalent to lack of jurisdiction. The failure of respondents to perfect their appeal to the Office of the President, while regrettable, did not preclude them from seeking recourse through certiorari when faced with void judgments from the DENR. On the DENR's grave abuse of discretion: The Court held that the DENR committed grave abuse of discretion by completely disregarding the CA Decision in CA-G.R. CV No. 67914, affirmed by the Supreme Court in G.R. No. 178990, which had already recognized respondents as the owners of Lot No. 1025. The DENR's pronouncements that ownership was not passed upon by the RTC and CA, and that Lot No. 1025 was public land, directly contradicted the established findings in the quieting of title case. This disregard for a final and executory judgment rendered the DENR's subsequent decisions void. On the dismissal of the quieting of title case and the issue of forum shopping: The Court did not directly rule on whether the dismissal of the quieting of title case for "lack of merit" bars a free patent application. However, it affirmed the CA's finding that petitioners were guilty of forum shopping. The CA ruled that the action for quieting of title constituted res judicata upon a subsequent application for free patent over the same land, and that these remedies were mutually exclusive. By disregarding the prior judicial pronouncements on ownership and proceeding with a public land application, petitioners engaged in forum shopping, which led to the dismissal of their application.
Main Doctrine
A petition for certiorari under Rule 65 is not a substitute for an appeal that was lost due to the party's fault or negligence, unless the respondent court or tribunal acted with grave abuse of discretion equivalent to lack of jurisdiction. The DENR gravely abused its discretion by disregarding prior final and executory decisions recognizing respondents' ownership of Lot No. 1025, rendering its subsequent decisions void.