Heirs of Borras v. Heirs of Borras
REITERATIONFacts
The Antecedents: Procopio Borras was the registered owner of Lot No. 5275. Upon his death, the property was inherited by his children, and subsequently by their children, including Eustaquio Borras. The Heirs of Eustaquio Borras (respondents) claimed ownership of the lot in 2004, which was contested by the Heirs of Procopio Borras (petitioners). During barangay conciliation, petitioners discovered that the lot was registered in Eustaquio's name. Procedural History: While Procopio Borras was alive, Eustaquio Borras filed a petition for reconstitution of the title for Lot No. 5275 before the Court of First Instance (CFI) of Albay. On July 7, 1980, the CFI ordered the reconstitution of the original certificate of title in Procopio Borras' name and the issuance of a transfer certificate of title in Eustaquio Borras' name. Subsequently, Transfer Certificate of Title (TCT) No. 21502 was issued to Eustaquio. Petitioners filed an action for quieting of title, and the Regional Trial Court (RTC) declared TCT No. 21502 null and void and reinstated the original title in Procopio's name. The Court of Appeals (CA) reversed the RTC decision, ruling that the RTC lacked jurisdiction to nullify the title and that the proper remedies were an action for annulment of judgment before the CA or an action for reconveyance before the RTC. Petitioners then filed a petition for annulment of judgment with the CA, seeking to annul the CFI's July 7, 1980 Order. The CA dismissed this petition, finding no extrinsic fraud or absolute lack of jurisdiction by the CFI. The CA denied petitioners' motion for reconsideration. The Petition: Petitioners seek a review on certiorari of the CA's decision and resolution. They argue that the CA erred in not considering that a petition for annulment of judgment was the proper remedy, given their assertion that the CFI lacked jurisdiction over the subject matter and parties when it ordered the cancellation of the original title and the issuance of a new one in Eustaquio's name. Petitioners also contend that the annulment of judgment was the only available remedy as they only discovered the CFI's order in 2004, nearly 24 years later. They further argue that the CA erred in ruling that their proper remedy was an action for reconveyance before the RTC, rather than a petition for annulment of the CFI's decision over which the CA has jurisdiction.
Issue(s)
WHETHER OR NOT THE HONORABLE COURT OF APPEALS GRAVELY ERRED IN NOT CONSIDERING THAT THE PETITION FOR ANNULMENT OF JUDGMENT IS THE PROPER REMEDY RESORTED BY THE PETITIONERS GIVEN THAT THE RESPONDENT TRIAL COURT HAS NO JURISDICTION OVER THE SUBJECT MATTER AND OVER THE PARTIES WHEN IT ALLOWED THE CANCELLATION OF THE RECONSTITUTED TITLE IN THE NAME OF PROCOPIO BORRAS AND ORDERED THE ISSUANCE OF TRANSFER CERTIFICATE OF TITLE NO. 21502 IN FAVOR OF EUSTAQUIO BORRAS IN A RECONSTITUTION PROCEEDING. WHETHER OR NOT THE HONORABLE COURT OF APPEALS GRAVELY ERRED IN NOT TAKING INTO CONSIDERATION THAT THE PETITION FOR ANNULMENT OF JUDGMENT IS THE ONLY REMEDY AVAILABLE TO PETITIONERS AS THE ASSAILED JULY 7, 1980 ORDER OF THE RESPONDENT TRIAL COURT WAS DISCOVERED BY PETITIONERS ONLY IN 2004 OR ALMOST 24 YEARS FROM THE DATE THEREOF; AND WHETHER OR NOT THE HONORABLE COURT OF APPEALS GRAVELY ERRED IN RULING THAT PETITIONERS' PROPER REMEDY IS A CASE FOR RECONVEYANCE COGNIZABLE BY THE REGIONAL TRIAL COURT AND NOT A PETITION FOR ANNULMENT OF THE JULY 7, 1980 DECISION OF THE RESPONDENT TRIAL COURT OVER WHICH COURT OF APPEALS HAS JURISDICTION TO DECIDE.
Ruling
The petition is denied. The January 15, 2014 Decision and August 14, 2014 Resolution of the Court of Appeals in CA-G.R. SP No. 124946 are affirmed.
Ratio Decidendi
On the propriety of the Petition for Annulment of Judgment based on lack of jurisdiction: The Court reiterated that annulment of judgment may be based on lack of jurisdiction or extrinsic fraud. For lack of jurisdiction, it must be an absolute absence of jurisdiction over the person or the subject matter, not merely an abuse of jurisdictional discretion or acting in excess of jurisdiction. In this case, the CFI had jurisdiction over the petition for reconstitution. While it acted in excess of its jurisdiction by ordering the cancellation of the original title and issuing a new one in Eustaquio's name, this was an error in the exercise of jurisdiction, not a lack thereof. Such errors of judgment are subject to appeal, not annulment under Rule 47. The Court cited Lasala v. National Food Authority to emphasize that grave abuse of discretion amounting to excess of jurisdiction does not equate to an absolute lack of jurisdiction required for annulment. On the availability of other remedies and the proper recourse: The Court noted that a petition for annulment of judgment is an exceptional remedy available only when ordinary remedies are no longer available. The CA, in its previous decision (CA-G.R. CV No. 90004), had already pointed out that the petitioners could have filed an action for reconveyance before the RTC, which is a proper remedy for the rightful owner of land wrongfully registered in another's name. The CA's ruling in the annulment case also suggested that an action for reconveyance was still a viable option. The Court clarified that while the CA previously suggested annulment of judgment under Rule 47 as a recourse, this was in the context of attacking the cadastral court's decision for want or excess of jurisdiction. However, the petitioners' chosen ground for annulment (excess of jurisdiction) was not a valid basis under Rule 47. Therefore, the CA correctly dismissed the petition for annulment of judgment, as the proper remedy for the petitioners, given the circumstances, was an action for reconveyance.
Main Doctrine
An action for annulment of judgment based on lack of jurisdiction requires an absolute absence of jurisdiction, not merely an exercise of jurisdiction in excess thereof. Errors committed in the exercise of valid jurisdiction are merely errors of judgment subject to appeal, not annulment. When a court has jurisdiction over the subject matter and the parties, subsequent errors in judgment do not divest it of jurisdiction. An action for reconveyance is the proper remedy when a title is wrongfully or erroneously registered, respecting the decree of registration.