G.R. No. 86074 December 20, 1989
LILIA LIWAG, petitioner, vs. COURT OF APPEALS and HEIRS OF THE SPOUSES VICENTE S. CRUZ and JUANA EUSTAQUIO, respondents.

FACTS

The case originated from a petition for reconstitution of a lost title filed by Vicente S. Cruz. After the reconstitution and issuance of new titles in his name, Cruz ostensibly sold the properties to petitioner Lilia Liwag. Liwag later filed an omnibus motion in the same reconstitution case (LRC Case No. 80, pending in Branch 160, RTC Pasig), alleging the loss of her deed of sale and the owner’s duplicate certificates of title, and praying for the cancellation of the existing titles. The court granted her petition, cancelled the titles in Cruz’s name, and issued new ones in Liwag’s name. Subsequently, Liwag sold the properties to Teresita Paz.
The heirs of Vicente Cruz (private respondents) then filed a separate civil action (Civil Case No. 53389) in Branch 162 of the RTC Pasig against Liwag and Paz, seeking the annulment of the deeds of sale as simulated and the cancellation of Liwag’s titles. During the pendency of this case, private respondents and defendant Paz entered into a compromise agreement, which was approved by Branch 162. The agreement led to the cancellation of Liwag’s titles and the issuance of new ones in the names of the heirs and Paz. Liwag, claiming Paz had already reconveyed the property to her prior to the compromise, filed a petition for relief from judgment in Branch 162, which was denied.

ISSUE

The core issue is whether Branch 160 (the land registration court) had jurisdiction to entertain Liwag’s subsequent petition for the cancellation of the titles issued pursuant to the compromise judgment rendered by Branch 162.

RULING

The Supreme Court ruled that Branch 160 acted without jurisdiction. A land registration court, acting under its limited jurisdiction pursuant to Section 108 of P.D. No. 1529, cannot nullify titles issued by virtue of a final and executory judgment rendered by another branch of the same regional trial court. Liwag’s petition before Branch 160, though captioned as one for cancellation under Section 108, was in substance a collateral attack on the validity of the compromise judgment from Branch 162. Such an action for annulment of judgment falls outside the limited jurisdiction of a land registration court and, under the law then in force, was within the exclusive original jurisdiction of the Court of Appeals.
The legal logic is clear: a court of limited jurisdiction cannot review, reverse, or nullify the final orders of a coordinate court. The proper remedy for Liwag, if she believed the compromise judgment was vitiated by fraud, was to file a direct action for annulment of judgment in the proper forum, not to seek its indirect overthrow via a petition for cancellation in the land registration court. The Court of Appeals correctly annulled the orders of Branch 160 for having been issued without jurisdiction. The Supreme Court affirmed the appellate court’s resolutions, without prejudice to Liwag’s right to pursue the appropriate independent action.