GR L 59979; (August, 1990) (Digest)
G.R. No. L-59979 August 30, 1990
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. CAMILO PAREJA, LEONARDO CALAYO, AQUILINA MIRA, BALBINA CALAYO, JORGE JESALVA AND CARLITO MIRA, defendants-appellants.
FACTS
The spouses Victorio Llona and Victoria Llave filed an action to quiet title over two unregistered parcels of land against several defendants, including appellants. The Court of First Instance of Sorsogon rendered a decision by default on November 11, 1971, declaring the Llonas as owners and ordering the defendants to vacate. After possession was delivered to the Llonas pursuant to this final judgment, the defendants returned to the lands and gathered products. Consequently, the trial court found the defendants guilty of contempt in a resolution dated March 29, 1978.
The appellants contended they could not be held in contempt. They argued that the disputed lands were part of the public domain, and during the pendency of the contempt proceedings, they were awarded free patents and certificates of title over the same lands by the Bureau of Lands. They asserted that the trial court’s decision in the civil case had become functus officio and that jurisdiction over the land dispute lay exclusively with the Bureau of Lands, not the courts.
ISSUE
Whether the Court of First Instance had jurisdiction to try the action for quieting of title over the disputed unregistered lands, which were allegedly part of the public domain, and consequently, whether its contempt resolution was valid.
RULING
The Supreme Court reversed and set aside the trial court’s decision and contempt resolution for lack of jurisdiction. The legal logic is anchored on the doctrine of primary jurisdiction over public lands. The Court held that where the land subject of litigation is part of the alienable public domain, the Director of Lands, under the Department of Environment and Natural Resources, possesses the exclusive authority to administer, dispose of, and investigate conflicts regarding such lands.
While courts retain jurisdiction over possessory actions like forcible entry or accion publiciana that are based solely on prior physical possession, an action for quieting of title directly involves a determination of ownership. For unregistered lands claimed to be public domain, this question of ownership falls within the primary competence of the Bureau of Lands, not the regular courts. Since the trial court lacked jurisdiction over the subject matter from the onset, its November 1971 decision and the subsequent March 1978 contempt resolution were null and void. A judgment rendered without jurisdiction is a legal nullity. The Court noted that the Director of Lands had already conducted an investigation and issued free patents to the appellants, the validity of which administrative act stands until properly challenged in a separate proceeding.