G.R. No. 185082. November 28, 2016.
MANDAUE REALTY & RESOURCES CORPORATION AND MANDAUE CITY REGISTER OF DEEDS, PETITIONERS, VS. THE COURT OF APPEALS AND BANGKO SENTRAL NG PILIPINAS, RESPONDENTS.

FACTS

Bangko Sentral ng Pilipinas (BSP) filed a Complaint for Annulment of Title/Reconveyance against Mandaue Realty and Resources Corporation (MARRECO) before the Regional Trial Court (RTC) of Mandaue City, Branch 56. BSP sought to cancel MARRECO’s title and reinstate its own, arguing that a prior Order from RTC Branch 55, which had nullified BSP’s title and restored it to MARRECO, was void. MARRECO moved to dismiss the complaint, contending that RTC Branch 56 had no jurisdiction to annul a final judgment of a co-equal court and that the action was barred by res judicata.
The RTC Branch 56 granted MARRECO’s Motion to Dismiss, ruling it lacked jurisdiction as assuming it would intrude upon the domain of RTC Branch 55. BSP appealed this dismissal order to the Court of Appeals (CA) via a Notice of Appeal under Rule 41. MARRECO then filed a Motion to Dismiss Appeal with the CA, arguing that BSP’s appeal raised only pure questions of law, which should have been brought directly to the Supreme Court via a petition for review on certiorari under Rule 45, thus rendering the CA without jurisdiction.

ISSUE

Whether the Court of Appeals correctly denied MARRECO’s Motion to Dismiss Appeal by ruling that the issues raised by BSP in its appeal involved mixed questions of fact and law, not pure questions of law.

RULING

The Supreme Court denied the petition and upheld the CA’s resolutions. The Court clarified that a question of law arises when the doubt concerns the correct application of law or jurisprudence to a certain set of facts, which are deemed uncontested. A question of fact exists when the issue necessitates a review of the probative value of evidence or requires the calibration of the factual findings of the lower court. The Court found that BSP’s appeal to the CA assailed the RTC’s conclusion that it lacked jurisdiction—a conclusion based on its assessment of the allegations in the complaint and its relationship to the prior final judgment from another branch. Determining whether the RTC Branch 56 correctly dismissed the case for lack of jurisdiction required an examination of whether the action was truly one for annulment of judgment or a distinct action for annulment of title, and whether the principle of judicial stability or res judicata applied. This evaluation inherently involved an analysis of the facts as pleaded to arrive at a legal conclusion, constituting a mixed question of fact and law. Therefore, the appeal was correctly taken to the CA under Rule 41, not directly to the Supreme Court under Rule 45. The CA committed no grave abuse of discretion in denying the motion to dismiss.