GR 189950; (April, 2017) (Digest)
G.R. No. 189950 April 24, 2017
BERNADETTE S. BILAG, et al., Petitioners, vs. ESTELA AY-AY, et al., Respondents.
FACTS
Respondents filed a Complaint for Quieting of Title against petitioners before the Regional Trial Court (RTC) of Baguio City. They alleged that their predecessor-in-interest, Iloc Bilag, sold to them various portions of a 159,496-square meter parcel of land within the Baguio Townsite Reservation, and they have been in continuous possession since 1976. They sought to remove the cloud on their title created by petitioners’ refusal to honor the sales and their threats of dispossession.
Petitioners moved to dismiss the complaint on three grounds: (1) lack of jurisdiction, as the subject lands are untitled and form part of the public domain, placing jurisdiction with the Land Management Bureau; (2) prescription, laches, or estoppel, as the action was filed over 27 years after the sales; and (3) res judicata, citing a prior final and executory case (Civil Case No. 3934-R) where respondents’ claim of ownership over the same lands was dismissed for lack of merit. The RTC granted the motion and dismissed the case.
ISSUE
Whether the RTC correctly dismissed the complaint for Quieting of Title.
RULING
The Supreme Court reversed the Court of Appeals and reinstated the RTC’s dismissal, but solely on the ground of lack of jurisdiction. The Court held that the subject property is within the Baguio Townsite Reservation, which remains part of the inalienable public domain. Jurisdiction over disputes involving the disposition and management of lands of the public domain is vested by law in the Director of Lands, subject to the control of the Department of Environment and Natural Resources.
An action for quieting of title presupposes that the plaintiff has a valid title to the property. Since the land is part of the public domain, no private title can be legally acquired except through a valid grant from the government. The Deeds of Sale executed by Iloc Bilag, who had no valid title himself, could not confer any enforceable right upon the respondents. Consequently, the RTC had no jurisdiction to entertain the suit. The Court found it unnecessary to rule on the other grounds for dismissal, as a judgment without jurisdiction is void. The case was remanded to the RTC with instructions to dismiss the complaint for lack of jurisdiction.