G.R. Nos. 229164 & 229186, September 02, 2019
Mercedes Tolentino Soliman, Heirs of Angeles Tolentino-Angeles, namely: Gracia S. Panes, Edgar T. Salvosa, Benjamin T. Salvosa and Sonia I. Mendoza, Heirs of Rafael Tolentino, namely: Leah T. Baena, Rene Angel Tolentino and Robert Tolentino, Petitioners, vs. Heirs of Ramon Tolentino, namely: Marilou T. Loiue, Antonio I. Tolentino, Elsa T. Calaustro, Dolores T. Tolentino, Jocelyn T. Duran, Teresita T. Thomas, Susan T. Clasio and Remigio Manchus, Respondents.

FACTS

Spouses Doroteo Tolentino and Engracia Dela Cruz were the registered owners of a parcel of land covered by Original Certificate of Title (OCT) No. RO 529 (263). Their children were Ramon, Angeles, Rafael, Carmen, and Mercedes. On August 25, 1977, Ramon filed a petition for the reconstitution of the lost OCT before the Court of First Instance (CFI) of Pili, Camarines Sur, praying that the reconstituted title be issued in his name. The CFI granted the petition in an Order dated January 20, 1978, declaring the original title lost and ordering the Register of Deeds to reconstitute it and issue a new title in the name of Ramon. Consequently, Transfer Certificate of Title (TCT) No. 3153 was issued in Ramon’s name on April 4, 1978.
On August 29, 2012, Mercedes, the heirs of Angeles, and the heirs of Rafael (petitioners) filed a petition for annulment of TCT No. 3153, enforcement of an agreement of partition, and reconveyance with damages against the heirs of Ramon (respondents). Petitioners contended that the land was co-owned by all heirs and that an Agreement of Partition had been executed among the siblings, allocating specific portions to each, following Ramon’s assurance that their shares would be protected despite the title being in his name. They alleged that a portion of the land was placed under agrarian reform, with only Ramon receiving compensation, but their possession of their respective portions remained undisturbed until one of Ramon’s heirs began claiming exclusive ownership.
The Regional Trial Court (RTC), in an Order dated February 22, 2013, ruled on the invalidity of the CFI Order insofar as it directed the issuance of a title in favor of Ramon for want of jurisdiction. This was affirmed in an Order dated April 15, 2013. Respondents assailed these orders via a Petition for Certiorari (CA-G.R. SP No. 130055). Subsequently, petitioners filed a Motion for Summary Judgment. The RTC, in an Order dated May 9, 2014, declared the January 20, 1978 CFI Order valid only for the reconstitution of the title but void regarding the issuance of TCT No. 3153 in Ramon’s name, for having been issued without jurisdiction.
Respondents appealed the RTC’s May 9, 2014 Order (CA-G.R. CV No. 102933). The Court of Appeals consolidated the appeal with the certiorari petition. Applying the doctrine of judicial stability/non-interference, the CA, in a Decision dated April 29, 2016, annulled and set aside the RTC’s February 22, 2013 and April 15, 2013 Orders, reversed and set aside the May 9, 2014 Order, and dismissed the complaint for annulment of title. The CA held that the RTC erred in declaring void the CFI Order issued by a co-equal court. Petitioners’ motion for reconsideration was denied in a Resolution dated November 23, 2016.

ISSUE

Whether or not the Court of Appeals erred in dismissing petitioners’ complaint for annulment of title by applying the doctrine of non-interference (judicial stability).

RULING

No, the Court of Appeals did not err. The Supreme Court affirmed the CA’s decision, denying the petition.
The doctrine of judicial stability or non-interference prohibits a court of concurrent jurisdiction from interfering with the judgment of another co-equal court. It ensures the orderly administration of justice by proscribing a co-equal court from exercising jurisdiction over a case already decided by another. A court that acquires jurisdiction over a case has exclusive jurisdiction over its judgment and incidents. Orders and decisions of a competent court cannot be altered, modified, or amended by another court of concurrent jurisdiction. This is fortified by Section 9(2) of Batas Pambansa Blg. 129, which grants the Court of Appeals exclusive original jurisdiction over actions for annulment of judgments of Regional Trial Courts.
The Supreme Court found that petitioners’ attempt to distinguish between annulling the TCT and annulling the CFI Order was unavailing. The records showed that the complaint assailed the issuance of TCT No. 3153, which stemmed directly from the CFI Order. The RTC, in its February 22, 2013 Order, explicitly found the CFI Order “null and void” for lack of jurisdiction insofar as it ordered the issuance of a new title in Ramon’s name, arguing the CFI exceeded its authority by granting a title in a new name instead of merely reconstituting the original. This pronouncement constituted an amendment of the earlier CFI decision, a clear violation of the doctrine of non-interference.
Citing Adlawan v. Joaquino, the Supreme Court clarified that a petition for annulment of a title issued pursuant to an RTC (formerly CFI) order of reconstitution, filed in another RTC branch, violates judicial stability. Such an action should be filed with the Court of Appeals. The RTC, as a co-equal court, had no jurisdiction to annul the reconstitution ordered by the CFI. Consequently, the RTC Order issued in violation of this doctrine was a void judgment with no legal effect.