G.R. No. 217120. April 18, 2016.
REPUBLIC OF THE PHILIPPINES, PETITIONER, VS. THE HEIRS OF SPOUSES FLORENTINO AND PACENCIA MOLINYAWE, REPRESENTED BY MARITES MOLINYAWE AND FRED SANTOS, RESPONDENTS.

FACTS

On May 16, 1960, criminal cases for malversation were filed against Florentino Molinyawe. In the same year, the Republic, through the OSG, filed a forfeiture case under R.A. No. 1379 against Florentino and respondents (the heirs) involving parcels of land covered by TCT Nos. 75239, 76129, and 77577, registered in the names of third parties. The Republic claimed these properties were illegally acquired by Florentino. On November 18, 1960, a notice of lis pendens for the forfeiture case was annotated on the titles. On September 22, 1972, the CFI-Pasig declared the sales null and void and ordered the properties forfeited in favor of the Republic. This decision became final and executory on August 23, 1974. A writ of execution was issued on February 14, 1975, but the Republic failed to cause the cancellation and transfer of the titles for over 30 years, as Florentino did not surrender the owner’s duplicate certificates. Meanwhile, on January 12, 1973, Florentino was acquitted in the malversation cases.
On July 9, 2010, respondents filed a Complaint/Petition with the RTC-Branch 57, Makati (Civil Case No. 10-658), praying for cancellation of the lis pendens and for quieting of title on the ground of prescription due to the Republic’s non-execution of the 1972 forfeiture decision. On October 6, 2010, the Republic annotated the 1972 decision on the titles. On December 5, 2010, the Republic filed a separate petition (LRC Case No. M-5469) with the RTC-Branch 138, Makati, for annulment of the owner’s duplicate copies and issuance of new ones. On September 12, 2011, the RTC-Branch 138 granted the petition, declared the owner’s duplicates null and void, and directed the issuance of new ones in the Republic’s name. This decision became final. On April 12, 2012, the Register of Deeds cancelled the old titles and issued new ones (TCT Nos. 006-2012000526, 006-2012000527, and 006-2012000528) in the Republic’s name.
Subsequently, on June 10, 2013, respondents filed a Motion to Admit Amended and Supplemental Petition in Civil Case No. 10-658. The RTC-Branch 57 admitted it via Orders dated September 6, 2013, and November 19, 2013. The Republic filed a Rule 65 petition for certiorari with the CA, arguing the RTC-Branch 57 had no jurisdiction, the amendment sought a review of a final decision of a co-equal court, and it was a collateral attack on the new titles. The CA dismissed the petition, ruling the RTC-Branch 57 did not commit grave abuse of discretion, had jurisdiction over quieting of title, and opined that the LRC decision was “flawed” as it did not consider Florentino’s acquittal. The Republic elevated the case to the Supreme Court.

ISSUE

1. Whether the RTC-Branch 57 committed grave abuse of discretion in admitting the Amended and Supplemental Petition, given it allegedly had no jurisdiction over Civil Case No. 10-658.
2. Whether the CA went beyond its jurisdiction under Rule 65 when it ruled that the civil forfeiture case was contingent or dependent on the criminal case.

RULING

The Supreme Court GRANTED the petition, REVERSED and SET ASIDE the CA Decision, and ordered the DISMISSAL of Civil Case No. 10-658.
1. Yes, the RTC-Branch 57 committed grave abuse of discretion. The original Complaint/Petition was essentially one for cancellation of the lis pendens annotation. Under Section 77 of P.D. No. 1529, a notice of lis pendens may be cancelled only by the court where the action was filed. The main action (the forfeiture case, Civil Case No. 6379) was filed with the CFI-Pasig, not with RTC-Branch 57. Therefore, RTC-Branch 57 had no jurisdiction to order the cancellation. An amendment of a pleading is not permissible when the court has no jurisdiction over the original complaint. By admitting the Amended and Supplemental Petition, which sought to nullify the final and executory decision of RTC-Branch 138 in the LRC case and the titles issued in the Republic’s name, RTC-Branch 57 effectively allowed a collateral attack on a Torrens title and a review of a final judgment of a co-equal court, which constitutes grave abuse of discretion.
2. Yes, the CA went beyond its jurisdiction. In a Rule 65 petition, the CA’s review is limited to determining whether the lower court acted without or in excess of jurisdiction or with grave abuse of discretion. The CA’s discussion declaring the LRC decision “flawed” because it did not consider Florentino’s acquittal in the malversation case was an extraneous and superfluous ruling. A civil forfeiture proceeding under R.A. No. 1379 is an action in rem, independent of any criminal proceeding. The acquittal in the criminal case does not affect the final judgment in the forfeiture case. The CA itself noted this issue was not within the thrust of a certiorari petition, making its pronouncement a clear excess of jurisdiction.
The Court held that the proper remedy for respondents, if any, was to file the necessary motion or action before the court having jurisdiction over the main forfeiture case, subject to applicable rules, noting that prescription and estoppel do not generally lie against the State.