G.R. No. L-12602; April 25, 1961
LUIS PINEDA, plaintiff-appellee, vs. COURT OF FIRST INSTANCE OF DAVAO, ERIBERTO UNSON, in his capacity as Provincial Sheriff Ex-Oficio of Davao and POTENCIANA PLANDO, defendants-appellants.

FACTS

Potenciana Plando filed Civil Case No. 959 against Luis Pineda and Bruno Ramirez, claiming ownership and possession of a homestead lot. Pineda and Ramirez were declared in default for failure to answer, and a 1953 decision declared Plando the lawful owner and possessor. Their motions for relief from the default judgment were denied, and their subsequent petition for certiorari with the Court of Appeals, challenging the denial of their motion to dismiss and the default order, was dismissed. The Supreme Court also denied their petition for review. The decision became final and executory.
Subsequently, Luis Pineda instituted the present action to annul a portion of that final decision. He argued that the declaration of ownership over a public land homestead was void for lack of jurisdiction, asserting that such determination was exclusively vested in the Bureau of Lands, where a separate administrative case between the parties was pending.

ISSUE

Whether the Court of First Instance of Davao acted without jurisdiction in rendering a decision that declared a party the lawful owner of a homestead application, thereby rendering that portion of its judgment void and subject to collateral attack.

RULING

The Supreme Court reversed the trial court’s decision annulling the prior judgment and dismissed Pineda’s complaint. The Court held that the principle of exhaustion of administrative remedies, while requiring that such remedies be pursued first, affects the existence of a cause of action, not the court’s jurisdiction. Courts of First Instance possess general original jurisdiction over civil actions involving title to or possession of real property under Republic Act No. 296 . Therefore, the court in Civil Case No. 959 had jurisdiction over the subject matter.
Consequently, even if the court erred in deciding the case while an administrative proceeding was pending—which would have been a proper ground for dismissal for lack of cause of action—such error did not negate its fundamental jurisdiction. A judgment rendered by a court with jurisdiction, even if erroneous, is not void but merely voidable, and must be challenged through timely appeal or appropriate direct attack. Since Pineda allowed the decision to become final and executory, and his prior certiorari petition raising the same jurisdictional issue was resolved against him, the judgment attained immutability. It could no longer be collaterally attacked in a separate action for annulment. The Court emphasized that the doctrine of finality of judgment precludes reopening settled matters.