G.R. No. L-17419; June 30, 1962
MARIA FAMA FLORENTIN, plaintiff-appellee, vs. LAZARO GALERA, ET AL., defendants, LAZARO GALERA, defendant-appellant.

FACTS

Maria Fama Florentin filed a complaint for reinvindication against Lazaro Galera to recover a parcel of land in La Union. Florentin based her claim on a Transfer Certificate of Title derived from an original free patent granted to Fernando Nantes. Galera defended his possession, alleging ownership through open, continuous, and peaceful possession for over sixty years and asserting that the original certificate was obtained by fraud. The Court of First Instance of La Union rendered judgment in favor of Florentin, declaring her the owner entitled to possession and ordering Galera to deliver the land and pay annual rentals. This judgment became final and executory.
Subsequently, Florentin moved for the demolition of Galera’s house on the property. The court issued the demolition order, prompting Galera’s appeal. He contended that the order, and the underlying judgment it enforced, were null and void for lack of jurisdiction. His argument centered on the allegation that the land, having been acquired by free patent, was sold within the five-year prohibitory period under Section 118 of the Public Land Law (C.A. 141), rendering the conveyance to Florentin’s predecessor void ab initio.

ISSUE

Whether the trial court acted without jurisdiction in rendering the judgment for reinvindication and issuing the subsequent demolition order, on the ground that the plaintiff’s title was allegedly void due to a violation of the Public Land Law.

RULING

The Supreme Court dismissed the appeal, upholding the demolition order. The Court clarified the crucial distinction between lack of jurisdiction and lack of cause of action. Jurisdiction is conferred by law and pertains to the court’s authority to hear and decide a case. The complaint was for reinvindication of real property, a matter squarely within the original jurisdiction of the Court of First Instance under the Judiciary Act. No defects in the acquisition of jurisdiction over the parties were alleged.
Galera’s defense—that Florentin’s title was void due to an alienation within the prohibited period—pertained not to jurisdiction but to the merits of her cause of action. It was a matter of defense that should have been fully litigated and resolved during the trial. Even assuming the trial court erred in its appreciation of this defense and the evidence, such error would be one of judgment, not jurisdiction. A judgment rendered with jurisdiction, even if arguably erroneous, remains valid and becomes immutable upon finality. The principle of res judicata applies, and parties cannot reopen issues conclusively settled by a final judgment. Therefore, the final judgment ordering Galera to deliver possession was valid and enforceable, and the order of demolition was a proper ancillary remedy to execute that final judgment.