Go Ramos-Yeo v. Chua
REITERATIONFacts
The Antecedents: The case involves a dispute over land titles. The Spouses Chua filed an accion reinvindicatoria against Marilyn Go Ramos-Yeo, Laurence Go, Montgomery Go (the Gos), and Multi-Realty Development Corporation (Multi-Realty). The Regional Trial Court (RTC) issued an Amended Decision in favor of the Spouses Chua. The Gos and Multi-Realty filed an Amended Petition for Annulment of Judgment, arguing that the RTC did not acquire jurisdiction over their persons due to invalid substituted service of summons and over the subject matter because the accion reinvindicatoria was a disguised attack on their certificates of title. Procedural History: The Court of Appeals (CA) denied the Amended Petition for Annulment of Judgment. The Supreme Court, in a prior Decision, reversed the CA, finding that the RTC lacked jurisdiction over the persons of the Gos due to invalid substituted service and over the subject matter as the accion reinvindicatoria was a collateral attack on the certificates of title. The Supreme Court annulled the RTC proceedings and ordered the Register of Deeds to cancel amendments made to the titles and reinstate the original boundaries. The Petition: The Spouses Chua filed a Consolidated Motion for Reconsideration of the Supreme Court's Decision, raising several arguments, including that the issues were already passed upon by the CA, that the issue of substituted service was factual, that the RTC had jurisdiction over the accion reinvindicatoria, and questioning the simultaneous promulgation of the Decision and Resolution.
Issue(s)
Whether the Supreme Court committed a reversible error in its November 5, 2018 Decision regarding procedural missteps. Whether the RTC acquired jurisdiction over the persons of the Gos due to the validity of the substituted service of summons. Whether the Gos were guilty of evident avoidance, impacting the validity of substituted service. Whether the RTC acquired jurisdiction over the subject matter of the accion reinvindicatoria. Whether the Spouses Chua's complaint for accion reinvindicatoria constituted a collateral attack on the certificates of title, and whether the Gos and Multi-Realty are barred by laches.
Ruling
The Motion for Reconsideration is DENIED with FINALITY. The Court reiterates its November 5, 2018 Decision, which granted the petitions, reversed and set aside the CA's Decision and Resolution, and annulled 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 is ordered to cancel amendments to the Transfer Certificates of Title of the Gos and Multi-Realty and reinstate their original boundaries.
Ratio Decidendi
On the validity of the Supreme Court's Decision and Resolution promulgation: The Court clarified that no procedural misstep occurred. The hard copies of the Comments were filed by the parties on October 4 and 5, 2018, respectively, which were duly received and considered. The subsequent directive to file soft copies was for compliance with e-filing and paper efficiency rules and did not preclude the Court from resolving the case, as all necessary pleadings had been submitted and assessed. On the propriety of substituted service of summons: The Court reiterated that the determination of the propriety of substituted service is a question of law, thus falling within the purview of a Rule 45 petition. It found that Deputy Sheriff Bienvenido Liboro failed to exert serious efforts to personally serve the summons on the Gos. The sheriff did not prove at least three attempts at personal service nor offer justification for its ineffectualness. Furthermore, the sheriff did not validate if the recipient of the substituted service, Patricio Alampay, was of suitable age and discernment to comprehend the import of the summons and deliver it promptly to the Gos. Consequently, the substituted service was improper, and the RTC did not acquire jurisdiction over the persons of the Gos. On the claim of evident avoidance: The Court rejected the Spouses Chua's argument that the Gos were guilty of evident avoidance. The receipt of a motion for reconsideration by Alampay did not conclusively prove that the Gos flagrantly refused or avoided service of summons. This fact alone did not validate the requisites for a valid substituted service, and the impossibility of personal service was wanting in this case. On the jurisdiction over the subject matter: The Court reaffirmed that the accion reinvindicatoria complaint was a disguised attempt to review a final decree of registration, in violation of Section 108 of PD 1529. The RTC's judgment materially altered the boundaries of the properties owned by the Gos and Multi-Realty, affecting the integrity of their titles. Therefore, the case fell under the jurisdiction of a land registration court, not an ordinary civil court. On the collateral attack and laches: The Court reiterated that the RTC's Amended Decision was null and void due to lack of jurisdiction over the subject matter. Consequently, the Gos and Multi-Realty were not barred by laches, as no valid rights were conferred upon the Spouses Chua or obligations imposed against the parties by the void judgment.
Main Doctrine
A complaint for accion reinvindicatoria that seeks to re-open, amend, or review transfer certificates of title constitutes an indirect and collateral attack on the validity of such titles, violating Sections 32 and 108 of PD 1529. Such an action falls within the jurisdiction of a land registration court, not an ordinary civil court. Furthermore, substituted service of summons is invalid if the sheriff fails to exert serious efforts to personally serve the summons and to justify the impossibility of personal service.