G.R. No. 201821 . September 19, 2018
PABLO B. MALABANAN, PETITIONER, VS. REPUBLIC OF THE PHILIPPINES, RESPONDENT.

FACTS

The Republic of the Philippines, through the Office of the Solicitor General, filed an action for reversion and cancellation of title (Civil Case No. C-192) against Pablo B. Malabanan and other registered owners. The Republic alleged that the titles in question were derived from an Original Certificate of Title (OCT No. 0-17421) purportedly issued pursuant to a decree in a land registration case (LRC Record No. 50573). However, an investigation revealed that no copy of the judgment in that land registration case could be found. The Republic further asserted that the land covered by the title was within an unclassified public forest, making it inalienable public domain that could not be privately owned.
Pablo Malabanan moved to dismiss the complaint, arguing that the Regional Trial Court (RTC) lacked jurisdiction. He contended that the action effectively sought the annulment of the judgment and decree in the land registration case, a matter falling under the exclusive appellate jurisdiction of the Court of Appeals. The RTC agreed and dismissed the case, citing its lack of jurisdiction and noting that a similar complaint had been previously dismissed. The Republic appealed, but the RTC denied due course to its notice of appeal. The Republic then elevated the matter to the Court of Appeals via certiorari.

ISSUE

Whether the Regional Trial Court has jurisdiction over the Republic’s action for reversion and cancellation of title, which challenges the validity of a certificate of title allegedly issued without a valid judgment from a land registration court.

RULING

Yes, the Regional Trial Court has jurisdiction. The Supreme Court affirmed the decision of the Court of Appeals, which had set aside the RTC’s dismissal order and remanded the case for trial.
The Court clarified the distinction between an action for annulment of judgment and an action for reversion. An action for annulment of judgment directly assails the final judgment of a court, and jurisdiction over such actions involving RTC judgments is vested in the Court of Appeals. In contrast, an action for reversion, instituted by the State under Section 101 of the Public Land Act, is directed against the certificate of title itself, not the judgment that purportedly authorized its issuance. The Court emphasized that jurisdiction is determined by the allegations in the complaint. Here, the Republic’s complaint alleged that the title was void because the land was inalienable forest land and, critically, that the judgment decreeing registration was non-existent. The action, therefore, sought the cancellation of a title allegedly issued without any valid judicial order, which is a direct attack on the title, not on a judgment. Consequently, the case falls within the RTC’s original jurisdiction over actions where the subject of litigation is incapable of pecuniary estimation, such as actions for reversion of public land. The RTC erred in dismissing the case for lack of jurisdiction. The case was remanded to the RTC for further proceedings on the merits.