GR L 35563; (April, 1985) (Digest)
G.R. No. L-35563. April 30, 1985.
BETHEL TEMPLE, INC., petitioner, vs. GENERAL COUNCIL OF THE ASSEMBLIES OF GOD, INC., respondent.
FACTS
In a prior action to quiet title (Civil Case No. 64924), the Court of First Instance of Manila adjudicated ownership of two parcels of land in favor of respondent General Council of the Assemblies of God, Inc., a U.S.-based corporation. The judgment became final and executory. Petitioner Bethel Temple, Inc., a defendant in that case, later filed a separate action (Civil Case No. 83276) to annul that final judgment. The sole ground for annulment was alleged lack of jurisdiction, contending that the court in the prior case had no authority to award land to the respondent foreign corporation. Petitioner argued this was because the Parity Amendment to the 1935 Constitution, which allowed such acquisition, was invalidly ratified, and that, in any event, such rights had expired.
The trial court dismissed the annulment case. It ruled that the validity of the Parity Amendment had been settled by the Supreme Court in Mabanag vs. Lopez Vito, and that the court which rendered the quiet title judgment possessed jurisdiction over the subject matter and parties. Petitioner now seeks a review of that dismissal.
ISSUE
Whether the trial court in Civil Case No. 83276 correctly dismissed the action for annulment of the final judgment in Civil Case No. 64924.
RULING
Yes, the dismissal was correct. The petition for annulment was properly denied. An action for annulment of judgment based on lack of jurisdiction requires a showing that the court was devoid of authority over the subject matter or the parties. The Court of First Instance was a court of general jurisdiction expressly empowered by law to adjudicate cases like the quiet title action. Its potential error in applying the Parity Amendment as a basis for its decision did not negate its fundamental jurisdiction to hear and decide the case. A judgment rendered by a court with jurisdiction, even if arguably erroneous, is not void but merely voidable, and becomes final and immutable if not appealed.
The Supreme Court clarified the substantive merits to dispel any lingering doubt. The validity of the Parity Amendment was conclusively upheld in Mabanag vs. Lopez Vito. Furthermore, under the Transitory Provisions of the 1973 Constitution, titles to private lands acquired by qualified U.S. citizens or corporations before July 3, 1974, remained valid against other private persons. Thus, respondent’s title, acquired by purchase prior to that date, was preserved as against petitioner’s claim. The annulment action, therefore, had no legal basis. The petition was dismissed.
