GR 139306; (August, 2000) (Digest)
G.R. No. 139306 ; August 29, 2000
MARIA MERCEDES NERY, et al., petitioners, vs. GABRIEL LEYSON, et al., respondents.
FACTS
Petitioners, heirs of Mercedes del Rio, claimed an interest in a parcel of land in Lapu-Lapu City. Their mother’s share was annotated on the original title. In 1964, respondents, the Leysons, filed Civil Case No. R-8646 against, among others, the deceased Mercedes del Rio, seeking the annulment of the reconstituted title and the declaration of their own title as valid. The trial court ruled for the Leysons, a decision affirmed by the Court of Appeals in 1976, which became final and executory. Petitioners, asserting they were not parties to that case and their mother was already dead when it was filed, initiated a new action in 1991 before the Regional Trial Court (RTC) of Lapu-Lapu City. They sought a declaration of nullity of the Leysons’ title and the judicial proceedings in Civil Case No. R-8646.
The RTC dismissed the complaint. On appeal, the Court of Appeals affirmed the dismissal, prompting the petitioners to elevate the case to the Supreme Court via a petition for review on certiorari.
ISSUE
Whether the Regional Trial Court had jurisdiction to annul the final judgment rendered in Civil Case No. R-8646 by another co-equal Regional Trial Court.
RULING
No, the Regional Trial Court had no jurisdiction. The Supreme Court affirmed the Court of Appeals’ dismissal, ruling squarely on the issue of jurisdiction. The legal logic is anchored on the doctrine of hierarchy of courts and the explicit statutory grant of jurisdiction. Under Section 9 of Batas Pambansa Blg. 129, as amended, the Court of Appeals is vested with exclusive original jurisdiction over actions for annulment of judgments of Regional Trial Courts.
The petitioners’ action before the RTC of Lapu-Lapu was, in substance, a collateral attack seeking to nullify the final and executory judgment in Civil Case No. R-8646. Regardless of the merits of their claim—such as the alleged lack of jurisdiction over their persons or the fact that their mother was deceased when sued—the RTC where they filed their complaint was devoid of authority to grant the relief sought. A regional trial court is a co-equal court of the RTC that rendered the challenged decision; it cannot annul or set aside the final judgment of another court of equal rank. The proper and exclusive venue for such an annulment action is the Court of Appeals. Consequently, the RTC correctly dismissed the complaint for lack of jurisdiction. The Supreme Court emphasized that jurisdiction over the subject matter is conferred by law and cannot be waived or circumvented.