GR 167120; (April, 2014) (Digest)
G.R. No. 167120 , April 23, 2014
RODOLFO V. FRANCISCO, Petitioner, vs. EMILIANA M. ROJAS, and the legitimate heirs of JOSE A. ROJAS, namely: JOSE FERDINAND M. ROJAS II, ROLANDO M. ROJAS, JOSE M. ROJAS, JR., CARMELITA ROJAS-JOSE, VICTOR M. ROJAS, and LOURDES M. ROJAS, all represented by JOSE FERDINAND M. ROJAS II, Respondents.
FACTS
The case involves a dispute over a portion of the 3,181.74-hectare Hacienda de Angono in Rizal. The hacienda was originally owned by Don Buenaventura Guido y Santa Ana, and upon his death, a portion was inherited by his sons Francisco and Hermogenes Guido. Decreto No. 6145 was issued in their favor in September 1911, and Original Certificate of Title (OCT) No. 633 was issued. On May 12, 1933, OCT No. 633 was cancelled and Transfer Certificate of Title (TCT) No. 23377 was issued. In 1942, the heirs of Francisco and Hermogenes adjudicated among themselves and transferred a one-half portion to Jose A. Rojas, predecessor-in-interest of the respondents. This adjudication was formalized in an Extra-Judicial Settlement of Estate With Quitclaim executed on December 17, 1973.
On March 29, 1976, Alfredo Guido, Sr., representing the heirs, filed a petition for reconstitution of TCT No. 23377, which was granted on the same date, resulting in the issuance of a reconstituted title. The property was subsequently subdivided, and titles were issued. The heirs, including the spouses Jose and Emiliana Rojas, sold the property to Pacil Management Corporation, which later reconveyed the lots to the former owners. Portions were later exchanged for corporate shares or renounced in favor of Alfredo Guido, Sr.
Meanwhile, on August 13, 1976, Rosalina V. Francisco, Carmen V. Francisco, Carmela V. Francisco, and petitioner Rodolfo V. Francisco (the Franciscos) filed an Application for Registration of Title over four parcels of land (Lots 1, 2, 3, and 4 of Plan Psu-04-001463) with the Court of First Instance (CFI) of Rizal, Branch 10, docketed as Land Registration Case (LRC) No. N-9293 (later LRC Case No. 95-0004). The respondents claimed these lots overlapped a portion of the area covered by TCT No. 23377 and were unaware of this application. The land registration court issued an Order of General Default on June 22, 1977. On September 15, 1977, the CFI rendered a Decision declaring the Franciscos as the true and absolute owners of the four lots. This decision became final and executory. On February 22, 1978, the court directed the issuance of a decree of registration.
In a separate proceeding (Civil Case No. 34242), the Republic of the Philippines filed a complaint for the declaration of nullity of Decreto No. 6145 and the owner’s duplicate copy of TCT No. 23377. The CFI of Rizal, Branch 155, dismissed the complaint and declared the decree and title genuine and authentic. This was affirmed by the Court of Appeals on July 12, 1988.
The respondents filed a petition for annulment of judgment with the Court of Appeals, seeking to nullify the September 15, 1977 Decision and subsequent orders in the land registration case. The CA granted the petition, nullifying the challenged decision and orders. The petitioner then filed this petition for review on certiorari.
ISSUE
The core issue is whether the Court of Appeals correctly nullified the September 15, 1977 Decision and related orders of the land registration court (CFI/RTC) in LRC Case No. 95-0004.
RULING
The Supreme Court DENIED the petition and AFFIRMED the Decision and Resolution of the Court of Appeals. The Court held that the land registration court’s September 15, 1977 Decision was void for lack of jurisdiction. The land registration court, acting as such, had no jurisdiction over the subject parcels of land because they were already covered by a Torrens title (TCT No. 23377 and its derivatives). The court’s jurisdiction in a land registration case is limited to original registration of title over lands that are not yet registered. Since the property was already registered under the Torrens system, the proper remedy for the Franciscos was an ordinary civil action for reconveyance or to quiet title, not a land registration proceeding. Consequently, the judgment rendered by a court without jurisdiction is void and can be attacked at any time. The Court of Appeals correctly annulled the void judgment and orders of the land registration court.