G.R. No. L-37963 February 28, 1974
CRISPINA R. GIANAN, (Represented by ROMEO GIANAN — Heir), petitioner, vs. HON. JORGE S. IMPERIAL, as Judge of the CFI-Camarines Sur, Branch II; ERNESTO OLANO, MARCELINO OLANO, SERVILLANO OLAÑO, JR., RUBEN OLAÑO and OSCAR OLAÑO, respondents.

FACTS

Petitioner Crispina R. Gianan filed an action in the Court of First Instance (CFI) of Camarines Sur, Branch II, to annul a final judgment rendered by Branch III of the same court. The judgment, issued in 1957, granted the adoption of the respondents by spouses Leoncio and Segundina Rubi. After pre-trial and the presentation of the plaintiff’s evidence, the respondent judge, on his own motion, raised the issue of jurisdiction. The court, relying on prior Supreme Court rulings, issued an order dismissing the complaint. It held that the jurisdiction to annul a judgment of one branch of the CFI belongs solely to that same branch, and any other branch attempting to do so acts without jurisdiction.

ISSUE

Whether Branch II of the CFI of Camarines Sur has jurisdiction to try and decide a complaint for the annulment of a final judgment rendered by Branch III of the same court.

RULING

Yes, Branch II possesses jurisdiction over the subject matter. The Supreme Court clarified the applicable legal principle. While earlier cases like Mas v. Dumara-og and Sterling Investment Corp. v. Ruiz suggested that only the rendering branch could annul its own judgment, the Court in Dulap v. Court of Appeals re-examined this doctrine. Jurisdiction over the subject matter of an action for annulment of judgment, which is incapable of pecuniary estimation, is conferred by law upon Courts of First Instance generally, not upon a specific branch. Therefore, any branch of the CFI within the judicial district inherently has the jurisdictional authority to entertain such an action, regardless of which branch rendered the original decision. The dismissal by respondent Judge Imperial was thus erroneous on the ground of lack of jurisdiction. However, the Supreme Court established a guideline rooted in judicial comity. As a matter of orderly and courteous interaction between co-equal branches, the annulment case is better heard by the branch that rendered the original judgment, especially if presided over by the same judge. Consequently, the Orders of dismissal were set aside. The case was ordered transferred to Branch III for continuation of trial if the same judge presided; otherwise, Branch II was to proceed and decide the case on the merits.