G.R. No. 159941 ; August 17, 2011
HEIRS OF SPOUSES TEOFILO M. RETERTA and ELISA RETERTA, namely: EDUARDO M. RETERTA, CONSUELO M. RETERTA, and AVELINA M. RETERTA, Petitioners, vs. SPOUSES LORENZO MORES and VIRGINIA LOPEZ, Respondents.

FACTS

Petitioners, heirs of Teofilo M. Reterta, filed a complaint for quieting of title and reconveyance in the RTC of Trece Martires City. They claimed ownership of a parcel of land in Cavite, inherited from their father, who they alleged acquired it through occupation and cultivation. They discovered a 1966 affidavit, purportedly executed by their father, waiving his rights to the land, which led to the issuance of Sales Certificate No. V-769 in favor of respondent Lorenzo Mores by the Department of Agriculture and Natural Resources, and subsequently Transfer Certificate of Title No. T-64071 in the respondents’ names. Respondents moved to dismiss the complaint, arguing the RTC lacked jurisdiction because the land was friar land and that petitioners lacked legal personality. The RTC granted the motion to dismiss on October 29, 2001, holding that under Act No. 1120, the Director of Lands (Lands Management Bureau) had exclusive administration and disposition of Friar Lands, including the determination of fraud in the procurement of the sales certificate, and thus the court had no jurisdiction. Petitioners’ motion for reconsideration was denied on February 21, 2002. Instead of appealing, petitioners filed a petition for certiorari with the Court of Appeals on May 15, 2002. The CA dismissed the petition on April 25, 2003, ruling that certiorari cannot substitute for a lost appeal, as the proper remedy against the RTC’s final order of dismissal was an appeal. The CA denied reconsideration on September 9, 2003.

ISSUE

Whether the Court of Appeals erred in dismissing the petition for certiorari, specifically whether certiorari was a proper remedy against the RTC’s order dismissing the complaint for quieting of title and reconveyance on the ground of lack of jurisdiction over friar land.

RULING

The Supreme Court granted the appeal, reversed the CA’s dismissal, and remanded the case to the RTC for further proceedings. The Court ruled that the CA erred in dismissing the petition for certiorari. While the general rule is that certiorari is not a substitute for a lost appeal, an exception applies when the trial court commits a grave abuse of discretion amounting to lack or excess of jurisdiction. The RTC committed such grave abuse by dismissing the complaint for lack of jurisdiction. The Court held that the RTC or MTC has original and exclusive jurisdiction over a complaint for quieting of title and reconveyance, regardless of the land being friar land. Act No. 1120, which grants the Director of Lands exclusive administration and disposition of friar lands, does not confer exclusive jurisdiction over judicial controversies involving such lands to the Land Management Bureau. Jurisdiction over the subject matter of such an action is determined by the allegations in the complaint, which in this case pertained to quieting of title and reconveyance, matters within the general jurisdiction of regular courts. Therefore, the RTC’s dismissal on jurisdictional grounds was a patent error correctible by certiorari. The Court also clarified that while the RTC’s order of dismissal was a final order normally appealable, the special civil action of certiorari was proper due to the trial court’s capricious, whimsical, and arbitrary exercise of judgment in dismissing the case.