G.R. No. 158643 ; June 19, 2007
ROSA BARICUATRO, CELSO BARICUATRO and ANITA BARICUATRO-OSMEÑA, Petitioners, vs. ROMEO CABALLERO, TASIANA CABALLERO, RUFO C. VERANO, PAULINA C. VERANO, CARMEN C. VERANO, PASCUAL C. VERANO, EDDIE C. VERANO, PEDRO CABALLERO, DELIO CABALLERO, VICTORINO CABALLERO, LAURO CABALLERO and CRISTOBAL CABALLERO, Respondents.

FACTS

Respondents filed a complaint for Quieting of Title and Cancellation of Free Patents against petitioners before the Regional Trial Court (RTC) of Cebu, Branch 16. Upon respondents’ motion, RTC Branch 16 issued an Order dated February 23, 1999, granting them leave to withdraw the complaint for re-filing in the proper court. Respondents then filed the same complaint with the Municipal Trial Court (MTC) of Naga, which dismissed it on March 1, 1999, for lack of jurisdiction. Respondents subsequently filed a Motion to Reinstate the original case with RTC Branch 16, which was denied in an Order dated May 26, 2000.
Thereafter, respondents re-filed the complaint with the RTC of Cebu City, and it was raffled to Branch 13. Petitioners moved to dismiss the case, alleging forum shopping and claiming that the RTC had lost jurisdiction due to the finality of Branch 16’s order denying reinstatement. RTC Branch 13 denied the motion to dismiss. Petitioners then elevated the matter to the Court of Appeals via a Petition for Certiorari, which was denied. Their motion for reconsideration was also denied.

ISSUE

Whether the Regional Trial Court (Branch 13) acquired jurisdiction over the re-filed complaint for Quieting of Title, or whether it lost jurisdiction due to the final order of another branch (Branch 16) denying the motion to reinstate the original case.

RULING

The Supreme Court denied the petition and affirmed the Court of Appeals. The RTC (Branch 13) validly acquired jurisdiction. The Court clarified that the Order of RTC Branch 16 dated May 26, 2000, which denied the Motion to Reinstate Case, was not a judgment or final order on the merits of the action. It was merely an interlocutory order resolving a procedural incident. Consequently, the principles of res judicata or bar by prior judgment do not apply. The denial did not preclude the respondents from re-filing the substantive complaint, as the original complaint had been voluntarily withdrawn by leave of court before any responsive pleading was filed.
The legal logic is anchored on the nature of jurisdiction and the structure of trial courts. Jurisdiction over the subject matter—an action for quieting of title and cancellation of free patents—is vested by law in the Regional Trial Courts. This jurisdiction is conferred on the court as a whole, not on a specific branch. The act of one branch (Branch 13) in assuming jurisdiction corrected the procedural misstep of another branch (Branch 16) in denying reinstatement. Branches of a single RTC are not distinct and separate tribunals; they are coordinate components of one court. Therefore, Branch 13’s assumption of jurisdiction over the re-filed complaint was proper and cured any incipient procedural defect. The respondents were not guilty of forum shopping, as there was no pending case or matter adjudicated on the merits involving the same cause of action.