Constantino v. Benitez
REITERATIONFacts
The Antecedents: Respondent Alejandria Benitez filed a petition for settlement of the intestate estate of her deceased husband, Romeo Benitez, who left real estate properties. The Regional Trial Court (RTC) declared Alejandria, Analiza Benitez, and Fritzie Joy Benitez as the sole heirs and appointed Alejandria as administrator. Subsequently, Alejandria and Analiza filed a petition for the issuance of new owner's duplicate copies of TCT Nos. T-27844 and T-26828, claiming the originals were lost. The cadastral court granted this petition. Petitioners Spouses Bernardo T. Constantino and Editha B. Constantino (Sps. Constantino) later purchased the lots covered by these TCTs from Ceazar Cu Benitez, allegedly Romeo's son. Sps. Constantino learned of the cadastral court's decision and filed a petition for annulment of judgment, alleging the Affidavit of Loss executed by Alejandria was perjured as the duplicate copies were not lost but were in the possession of Lolita Cu, then Ceazar, and subsequently transferred to Sps. Constantino. Procedural History: Sps. Constantino filed a motion for intervention in the intestate proceedings, seeking to exclude the subject lots from Romeo's estate and to cancel the notice of lis pendens. The intestate court denied this motion, citing the finality of the judgment and the late filing of the motion. Alejandria then moved for a writ of possession, which the intestate court granted, ordering Sps. Constantino to surrender possession of the lots. Sps. Constantino's motion for reconsideration was denied, and the writ of possession was executed. Sps. Constantino filed a petition for certiorari with the Court of Appeals (CA), assailing the orders granting the writ of possession. The Petition: The CA dismissed Sps. Constantino's petition for certiorari, affirming the intestate court's orders. The CA held that issues of ownership could not be resolved via intervention after judgment and that Sps. Constantino should have filed a petition for relief from judgment. Separately, the CA granted Sps. Constantino's petition for annulment of judgment concerning the cadastral court's decision, cancelling the new titles and reinstating the original TCTs in Romeo's name. The Supreme Court, in this petition, reviews the CA's dismissal of the certiorari petition concerning the writ of possession.
Issue(s)
Whether the intestate court committed grave error in issuing a writ of possession against Sps. Constantino. Whether Sps. Constantino's motion for intervention should have been given due course despite being filed after the judgment in the intestate proceedings had become final and executory. Whether possession of the subject properties should be returned to Sps. Constantino.
Ruling
The Supreme Court SET ASIDE the Decision and Resolution of the Court of Appeals. The Orders dated March 4, 2015 and March 23, 2015 of the Regional Trial Court of Batac in Spec. Proc. 4506-18 and the corresponding writ of possession issued are DECLARED null and void for lack of jurisdiction. Respondent Alejandria N. Benitez is ORDERED to surrender possession of the real properties covered by Transfer Certificate of Title Nos. T-27844 and T-26828 to petitioners Spouses Bernardo T. Constantino and Editha B. Constantino.
Ratio Decidendi
On the propriety of the writ of possession: The Supreme Court held that the intestate court committed grave error in issuing the writ of possession. A probate court exercises limited jurisdiction and cannot adjudicate title to property claimed by a third party adversely to the decedent, unless all parties consent or their interests are not prejudiced. The issuance of a writ of possession in this case, which effectively resolved the issue of ownership summarily without a full-blown trial, was beyond the intestate court's authority. A writ of possession is typically issued in specific instances like land registration, foreclosure, or execution sales, none of which applied here. Therefore, the order granting the writ of possession was void for lack of jurisdiction. On the motion for intervention: The Court found that Sps. Constantino's motion for intervention was filed beyond the period prescribed by Section 2, Rule 19 of the Rules of Court, which requires such motions to be filed before rendition of judgment. While the Court has, in exceptional cases, relaxed this rule, no sufficient reason was found to depart from the clear language of the rule in this instance. The intestate proceedings had long become final and executory, and the motion sought to reopen a terminated case, similar to the principle in Salandan v. Court of Appeals. Thus, the intervention could not be given due course. On the possession of the properties: Despite the denial of the motion for intervention, the Supreme Court ruled that possession of the subject properties should be returned to Sps. Constantino. This is because the Orders of the intestate court issuing the writ of possession were declared void for lack of jurisdiction. The erroneous issuance of the writ effectively recognized Alejandria's ownership without due process for Sps. Constantino, who were in possession of the property. The Court emphasized that conflicting claims of ownership must be resolved in a separate ordinary civil action, and depriving Sps. Constantino of the lots without an opportunity to be heard would violate due process. The Court also clarified that the cancellation of new titles and reinstatement of old ones in a separate annulment case did not automatically settle ownership, which still requires a separate action.
Main Doctrine
A Regional Trial Court acting as a probate court has limited jurisdiction and cannot adjudicate title to property claimed by a third party adversely to the decedent, unless all parties consent or the interests of third parties are not prejudiced. The issuance of a writ of possession in such a scenario is void for lack of jurisdiction. Furthermore, a motion for intervention filed after judgment has become final and executory is generally not allowed, absent exceptional circumstances.