GR 107595; (February, 1994) (Digest)
G.R. No. 107595 February 2, 1994
SPOUSES VIC B. MEDINA and DAISY R. MEDINA, petitioners, vs. HON. COURT OF APPEALS and MAYOR ERIBERTO R. RAMOS, SR., represented by his Atty.-in-Fact ERIBERTO J. RAMOS, JR., respondents.
FACTS
A fire destroyed the Office of the Register of Deeds of Quezon City, including the original certificates of title for T.C.T. Nos. 159937 and 159938 in the name of Mayor Eriberto R. Ramos, Sr. Ramos filed applications for administrative reconstitution of these titles with the Land Registration Authority (LRA). Subsequently, it was discovered that the LRA Reconstituting Officer, Benjamin M. Bustos, had issued an Order dated November 2, 1990, in Administrative Reconstitution Case No. Q-176(90), leading to the issuance of reconstituted titles RT-14989 and RT-14990 in the names of spouses Vic and Daisy Medina. These Medina titles covered the same parcels of land as Ramos’s titles, as evidenced by identical technical descriptions. An investigation by the LRA revealed that the Medina titles appeared to be fraudulent, with findings of erasures, tampering, and the adaptation of Ramos’s application data. Mayor Ramos filed a petition with the Court of Appeals seeking to annul the reconstitution order and cancel the Medina titles, invoking Section 10 of Republic Act No. 6732. The Court of Appeals granted the petition. The Medina spouses then appealed to the Supreme Court, contending that the Court of Appeals was not the “proper court” under Section 10 of R.A. No. 6732 to entertain such a petition.
ISSUE
Whether the Court of Appeals is the “proper court” referred to in Section 10 of Republic Act No. 6732, which allows an interested party deprived by fraud, accident, mistake, or excusable negligence to file a petition to set aside the decision of a reconstituting officer or Register of Deeds.
RULING
No. The Supreme Court ruled that the Court of Appeals is not the “proper court” under Section 10 of R.A. No. 6732. The law provides for a hierarchy of administrative review: first, an appeal to the LRA Administrator under Section 9, and then a judicial review via a petition for review to the Court of Appeals under Section 39 of the Judiciary Reorganization Act of 1980 (B.P. Blg. 129). Section 10 is a separate, special remedy available directly to an “interested party” who was unjustly deprived of participation in the reconstitution proceedings. This petition under Section 10 is an original action, not an appeal. The “proper court” for such an original action is the Regional Trial Court, which has general jurisdiction over all actions not expressly within the exclusive jurisdiction of other courts. Since R.A. No. 6732 does not specify which court has jurisdiction over petitions under Section 10, the Regional Trial Court, as a court of general jurisdiction, is the proper forum. Consequently, the decision of the Court of Appeals was declared null and void for lack of jurisdiction, without prejudice to Ramos’s right to file the proper action in the appropriate Regional Trial Court.