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PHILIPPINES VS. CA
DIGEST Admin
1 year ago

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Summary:
: 68 years after the promulgation of a Court of Appeals Decision, Petitioner petitioned for the annulment of judgement on the grounds of
lack of jurisdiction. CA Denied, but SC stated the petitioner was partly meritorious in that CA wrongly denied the petition on procedural
issues, in that petitioner needed to allege extrinsic fraud or lack of jurisdiction. SC stated lack of jurisdiction was expressly stated, but the
grounds relied upon by Republic were devoid of merit

Doctrine:
N/A

Facts:
June 1930, CFI found in favour of Sps. Carag, directed the Register of Deeds of Cagayan to issue to the sps. A OCT covering 7 Million
Square Meters.
De Dayag contested this by filing with the Regional Office of the DENR, opining that the CFi did not have jurisdiction.
In a Memorandum dated 9 September 1996, the Legal Division of the Land Management Bureau recommended to the Director of
Lands that an action for the cancellation of OCT No. 11585, as well as its derivative titles, be filed with the proper court. The Director
of Lands approved the recommendation.
 68 years later, June 1998, petitioner filed with the Court of Appeals a complaint for annulment of judgment, cancellation and
declaration of nullity of titles[9] on the ground that in 1930 the trial court had no jurisdiction to adjudicate a portion of the subject
property, which portion consists of 2,640,000 square meters.
Alleged said land was still timber land and thus inalienable.
CA dismissed the complaint. Alleged did not have power to annul such judgments, final orders and resolutions in civil actions.
 May only annul those which the ordinary remedies of new trial, appeal, petition for relief or other appropriate remedies
are no longer available
Also alleged that petitioner failed to allege either fraud or lack of jurisdiction in the complaint.
Issues raised by were factual in Nature.
Hence this petition

Issues Ratio:
WON CA was correct in dismissing the complaint? No

Complaint speicifcally stated that the CFI did not have jurisdiction to rule that the land was alienable, as the same is within the sole
purview of the Executive Branch

. The issuance of Decree No. 381928 and O.C.T. No. 11585 in the name of spouses Antonio Carag and Victoria Turingan, and all the derivative
titles thereto in the name of the Heirs and said spouses, specifically with respect to the inclusion thereto of timberland area, by the then Court of
First Instance (now the Regional Trial Court), and the Register of Deeds of Cagayan is patently illegal and erroneous for the reason that said Court
and/or the Register of Deeds of Cagayan did not have any authority or jurisdiction to decree or adjudicate the said timberland area of Lot 2472
Cad-151, consequently, the same are null and void ab initio, and of no force and effect whatsoever

As to the first issue, since PET alleged lack of jurisdiction, there was no need to allege other appropriate remedies were no longer
available. As to the third Section 6, Rule 47 of the Rules of Court provides:

SEC. 6. Procedure. - The procedure in ordinary civil cases shall be observed. Should a trial be necessary, the reception of evidence may be
referred to a member of the court or a judge of a Regional Trial Court.
Hence could have ruled on the factual issues.
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However the complaint must still be denied on the merits. According to jurisprudence, all land of the Republic were alienable per se.
Thus, unless specifically declared as mineral or forest zone, or reserved by the State for some public purpose in accordance with law, all
Crown lands were deemed alienable. In this case, petitioner has not alleged that the disputed portion had been declared as mineral or
forest zone, or reserved for some public purpose in accordance with law, during the Spanish regime or thereafter. Land maps attached
by petitioner did not show that the disputed patch of land was not inalienable.

Dispositive:
N/A

Other Notes:
This case digest was kindly submitted by Mr. Deriq David.

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