G.R. No. 178911 , September 17, 2014
EDUARDO D. MONSANTO, DECOROSO D. MONSANTO, SR., and REV. FR. PASCUAL D. MONSANTO, JR., Petitioners, vs. LEONCIO LIM and LORENZO DE GUZMAN, Respondents.

FACTS

The Home Development Mutual Fund (Pag-IBIG) requested intervention from Executive Judge Sinforiano A. Monsanto regarding an alleged anomalous auction sale conducted by Sheriff Lorenzo De Guzman. The sale involved a property mortgaged by Eduardo Monsanto, and Leoncio Lim emerged as the winning bidder. The judge recused himself due to relation to Eduardo and reassigned the matter to Judge Sibanah E. Usman of Branch 28. Judge Usman noted no formal petition or complaint was filed and referred the matter to the Office of the Court Administrator (OCA). Subsequently, Pascual Monsanto filed a “Motion to Lift Writ of Execution and Notice to Vacate” with the OCA, which directed Judge Usman to investigate and take action. Pag-IBIG later manifested that Eduardo’s loan had been restructured and it was withdrawing its petition for foreclosure. Leoncio Lim opposed this and filed an “Ex-Parte Motion for Issuance of Writ of Possession” with Branch 27. Decoroso Monsanto and Pascual Monsanto moved to intervene, claiming co-ownership. The RTC Branch 28 issued an Order denying the motion to lift the writ and granting the writ of possession to Leoncio Lim. Petitioners’ motion for reconsideration was denied. The Court of Appeals denied the Petition for Certiorari, finding no grave abuse of discretion by the RTC.

ISSUE

Whether the Regional Trial Court acquired jurisdiction over the subject matter to validly issue the assailed orders and writ of possession.

RULING

No. The Supreme Court ruled that the RTC never acquired jurisdiction over the subject matter. Jurisdiction over the subject matter is conferred by law and requires the filing of an appropriate initiatory pleading and payment of docket fees. The proceedings originated from a mere letter-request from Pag-IBIG, which was not an initiatory pleading that could commence an action. No complaint, petition, or application was ever filed by any party. The subsequent motions filed, including the “Motion to Lift Writ of Execution and Notice to Vacate,” were not initiatory pleadings as they were not claims for relief against another party and did not pay docket fees. The case captions used by the RTC (“In the Matter of the Extrajudicial Foreclosure of Mortgage” and “Home Development Mutual Fund (Pag-IBIG Fund), mortgagee, v. Eduardo Monsanto, mortgagor”) were improper as there was no actual case filed by Pag-IBIG against Eduardo Monsanto. Since the court did not acquire jurisdiction, all proceedings, including the July 1, 2005 and August 30, 2005 Orders and the Writ of Possession, are null and void. The Supreme Court granted the petition and declared the said orders and all proceedings emanating therefrom null and void.