G.R. No. 192975 & 192994; November 12, 2012
Republic of the Philippines and Samahang Kabuhayan ng San Lorenzo KKK, Inc. vs. Roman Catholic Archbishop of Manila

FACTS

The Republic of the Philippines filed a complaint for cancellation of titles and reversion against the Roman Catholic Archbishop of Manila (RCAM) before the Regional Trial Court (RTC) of Malolos, Bulacan. The Republic alleged that RCAM was the registered owner of eight parcels of land under Original Certificate of Title (OCT) No. 588, issued in 1917 pursuant to a land registration decree. The Republic contended that these specific lots (Nos. 43 to 50) were not included in the original 1915 land registration court decision, which covered different lot numbers. Furthermore, the lots were certified in 1983 as part of unclassified public lands and were declared alienable and disposable only in 1984. RCAM had sold the lots to other parties, leading to the issuance of transfer certificates of title.
RCAM filed a motion to dismiss the complaint, arguing that the action was essentially one for annulment of a land registration court judgment, which was beyond the jurisdiction of the RTC. The RTC denied the motion, finding a need to first ascertain factual issues regarding the issuance of the decree and title. RCAM elevated the matter to the Court of Appeals via certiorari.

ISSUE

Whether the Regional Trial Court has jurisdiction over the Republic’s action for cancellation of title and reversion.

RULING

Yes, the RTC has jurisdiction. The Supreme Court granted the petitions, annulled the Court of Appeals’ decision, and affirmed the RTC’s order denying the motion to dismiss. The Court clarified that the action filed by the Republic was not an action for annulment of judgment under Rule 47, which would fall within the exclusive original jurisdiction of the Court of Appeals. Instead, it was an ordinary civil action for reversion, which is within the general jurisdiction of the RTC.
The legal logic is grounded on the nature of the action and the principle of jurisdiction over the subject matter. An action for reversion, where the State seeks to revert land to the public domain on the ground that it was fraudulently or erroneously titled, is an action in personam that involves title to or interest in real property. Under Batas Pambansa Blg. 129, as amended, the RTC exercises exclusive original jurisdiction over all civil actions where the title to real property is involved, except for forcible entry and unlawful detainer. The Republic’s complaint did not directly assail the 1915 land registration court judgment itself. Rather, it sought the nullification of OCT No. 588 and its derivative titles based on the independent grounds that the lots were not part of the adjudicated property in the land registration case and were inalienable public land at the time of titling. This is a collateral attack on the title, which is permissible. The RTC, therefore, correctly assumed jurisdiction to hear evidence on these factual allegations. The Court of Appeals erred in re-characterizing the suit as one for annulment of judgment and in applying equitable estoppel against the State at the motion to dismiss stage, as such defenses require a full trial on the merits.