G.R. No. L-32651-52 August 31, 1971
LUCIO DAJUNOS, ET AL., petitioners, vs. HON. TEODULO C. TANDAYAG, ET AL., respondents.

FACTS

The dispute involves a 9-hectare parcel of land in Lanao del Norte. Petitioners, the Firmalos, are heirs of Ireneo Firmalo and were administratively awarded a free patent and Original Certificate of Title P-2881 in March 1969 by the Director of Lands, a decision affirmed by the Secretary of Agriculture and Natural Resources and, ultimately, the President. Respondents, the Tarucs, heirs of Daniel Taruc, base their claim on a final judgment dated October 28, 1968, rendered by respondent Judge Teodulo Tandayag in Civil Case No. 1218, which declared them the “equitable owners” of the land. The Tarucs filed this judicial action for quieting of title while the administrative free patent proceedings initiated by Daniel Taruc, which were protested by the Firmalos, were still pending. After obtaining their title, the Firmalos filed a new action, Civil Case No. 1528, for ownership and possession. Judge Hernando Pineda granted a preliminary mandatory injunction in favor of the Firmalos. However, upon Judge Pineda’s retirement, respondent Judge Tandayag reassumed jurisdiction and issued a writ of execution to enforce his 1968 decision, restoring possession to the Tarucs.

ISSUE

Whether the Court of First Instance, in Civil Case No. 1218, had jurisdiction to adjudicate ownership and possession of the disputed land while it was still part of the public domain and subject to ongoing administrative proceedings for a free patent.

RULING

The Supreme Court ruled that the lower court had no jurisdiction. The land was undisputedly public land at the time Civil Case No. 1218 was filed and decided. Jurisdiction over the disposition, administration, and alienation of public lands is vested exclusively in the Director of Lands, subject to the control of the Secretary of Agriculture and Natural Resources, by virtue of Commonwealth Act No. 141 (Public Land Act). Regular courts lack jurisdiction to determine who among conflicting claimants has a better right to a free patent or to adjudicate “equitable ownership” over public land. Such authority resides solely in the administrative agencies tasked with executing the public land laws. Consequently, the judgment in Civil Case No. 1218, having been rendered by a court without jurisdiction over the subject matter, is null and void. A void judgment can be assailed at any time and confers no rights. The Court set aside the 1968 decision, the subsequent writ of execution, and the order denying its recall. It ordered the reinstatement of the preliminary mandatory injunction in Civil Case No. 1528 and directed the lower court to proceed with the hearing of that case.