GR 162322; (March, 2012) (Digest)
G.R. No. 162322 ; March 14, 2012
Republic of the Philippines, Petitioner, vs. Bantigue Point Development Corporation, Respondent.
FACTS
Respondent Bantigue Point Development Corporation filed an application for original registration of title over a parcel of land with a total assessed value of ₱14,920 before the Regional Trial Court (RTC) of Rosario, Batangas. The RTC issued orders setting the case for initial hearing. The Republic filed its Opposition while the records were still with the RTC. Subsequently, the RTC Clerk of Court motu proprio transmitted the records to the Municipal Trial Court (MTC) of San Juan, Batangas, opining that the assessed value was below ₱100,000. The MTC then proceeded, granted the application, and its decision was affirmed by the Court of Appeals (CA). The CA ruled the Republic was estopped from questioning the MTC’s jurisdiction due to its participation and found respondent had proven the required possession. The Republic petitioned the Supreme Court, arguing it cannot be estopped from raising jurisdiction and that the MTC failed to acquire it.
ISSUE
Whether the MTC validly acquired jurisdiction over the land registration application.
RULING
The Supreme Court upheld the MTC’s jurisdiction but remanded the case for further proceedings. On jurisdiction, the Court held the Republic was not estopped from raising the issue. Jurisdiction over the subject matter, conferred only by law, can be questioned at any stage and cannot be waived or conferred by acquiescence. The exceptional doctrine of estoppel by laches from Tijam v. Sibonghanoy was inapplicable. Here, the Republic filed its Opposition with the RTC before the transfer and did not seek affirmative relief from the MTC, raising the jurisdictional challenge promptly on appeal, unlike the prolonged inaction in Tijam.
On the validity of jurisdiction, the Court found the MTC properly acquired it. Under BP 129, as amended, MTCs have delegated jurisdiction over land registration cases where the assessed value does not exceed ₱100,000. The total assessed value was ₱14,920, well within the limit. The RTC’s initial handling did not negate this; jurisdiction is determined by the assessed value alleged in the application. The RTC Clerk’s motu proprio transfer, though procedurally irregular, did not invalidate the MTC’s jurisdiction, which attached upon the filing of the compliant application. However, the Court remanded the case to determine if the land is alienable and disposable public land. The respondent’s evidence, a CENRO certification, was insufficient under prevailing jurisprudence, which requires a certification from the DENR Secretary or a Regional Technical Director to conclusively prove this essential requirement for registration.