Garcia v. Esclito
REITERATIONFacts
The Antecedents: In 1979, Antonio Garcia purchased a 29-hectare land. In 1998, he donated portions to his children and grandchildren, who then obtained certificates of title from the DENR under the Handog Titulo program. In 2003, respondents, holders of CLOAs from the DAR, filed a petition to annul the 1979 deed of sale and subsequent transfers, alleging violation of Section 6 of RA 6657 (Comprehensive Agrarian Reform Law of 1988) due to non-registration within three months of the law's effectivity. They contended this rendered the sale and subsequent titles void. Petitioners countered that the DENR, not the DARAB, had jurisdiction, that their titles could not be collaterally attacked, and that their patents predated the respondents' CLOAs. Procedural History: The DAR Provincial Adjudicator dismissed the respondents' petition for lack of jurisdiction, finding the land outside CARP coverage and the attack on the deed of sale a collateral attack on the titles. The DARAB reversed this, declaring the deed of sale and subsequent transfers void for non-compliance with RA 6657's registration requirement. The DARAB denied petitioners' motion for reconsideration. Petitioners then filed a petition for certiorari with the Court of Appeals (CA), assailing the DARAB's decision. While this petition was pending, petitioners also filed a separate direct complaint for cancellation of titles with the RTC. The CA denied the certiorari petition, affirming the DARAB's ruling. The Petition: Petitioners seek certiorari under Rule 65, arguing the CA gravely abused its discretion in affirming the DARAB's decision. They contend that the respondents' petition before the DARAB constituted an impermissible collateral attack on their Torrens certificates of title, which can only be challenged in a direct proceeding. They also argue that the DARAB exceeded its jurisdiction by declaring their certificates of title void. The Supreme Court noted that certiorari was not the proper remedy as an appeal was available, but granted due course in the interest of justice, finding the DARAB decision a patent nullity. The Court reinstated the Provincial Adjudicator's decision, holding that the respondents' action was a collateral attack on the petitioners' Torrens titles.
Issue(s)
Whether the CA committed grave abuse of discretion amounting to lack or excess of jurisdiction in rendering the assailed Decision and Resolution. Whether the respondents' petition before the Provincial Adjudicator constituted an impermissible collateral attack on the petitioners' Torrens certificates of title; and whether the DARAB had jurisdiction to declare the deed of sale and subsequent documents, including the certificates of title, void.
Ruling
The petition is meritorious. The Supreme Court set aside the Court of Appeals' Decision and Resolution, and reinstated the Provincial Adjudicator's Decision dismissing the respondents' petition. The Court found that the CA committed grave abuse of discretion in affirming the DARAB's decision, which was deemed a patent nullity.
Ratio Decidendi
On the propriety of the certiorari petition: The Court noted that petitioners availed of the wrong remedy by filing a petition for certiorari instead of an ordinary appeal. However, it held that certiorari may be allowed in the interest of justice when the questioned ruling is a patent nullity, as in this case, where the DARAB decision effectively affirmed by the CA was beyond its jurisdiction. The Court emphasized that while appeal is the plain, speedy, and adequate remedy, exceptions exist when broader interests of justice demand it, such as when the questioned order amounts to an oppressive exercise of judicial authority or is a patent nullity. On the nature of the attack on the Torrens titles, the DARAB's jurisdiction, the effect of the collateral attack, and the validity of the deed of sale and subsequent documents: The Court ruled that the respondents' petition before the Provincial Adjudicator constituted an impermissible collateral attack on the petitioners' Torrens certificates of title. Citing Section 43 of PD 1529, the Court reiterated that a certificate of title cannot be subjected to a collateral attack and can only be altered, modified, or cancelled in a direct proceeding. A collateral attack occurs when, in an action for a different relief, the validity of the title is incidentally questioned. The integrity and indefeasibility of land titles under the Torrens system are guaranteed and can only be questioned directly. The Court found that the DARAB gravely abused its discretion by giving due course to the respondents' appeal, which allowed a prohibited collateral attack. Furthermore, the DARAB exceeded its jurisdiction by effectively declaring the petitioners' certificates of title void based on this collateral attack. The Court clarified that the DARAB's jurisdiction pertains to agrarian reform matters, and the petitioners' titles were issued by the DENR, not through any CARP-related award. Therefore, the DARAB could not validly declare these DENR-issued titles void, especially through a collateral attack. The Court agreed with the Provincial Adjudicator that the attack on the deed of sale, which served as the link to the petitioners' titles, was a collateral attack. The annulment of the deed would consequently lead to the nullification of the titles. Since the attack was collateral and impermissible, the DARAB's reversal of the Provincial Adjudicator's dismissal was erroneous. The Court reinstated the Provincial Adjudicator's ruling that dismissed the respondents' petition.
Main Doctrine
A petition for certiorari is not the proper remedy when an ordinary appeal is available. However, certiorari may be allowed in the interest of justice if the questioned ruling is a patent nullity. An attack on a deed of sale pursuant to which a certificate of title was issued constitutes an impermissible collateral attack on the certificate of title, which can only be assailed in a direct proceeding.