The Supreme Court held that a Regional Trial Court (RTC) cannot annul the decision of another RTC of equal rank. This is rooted in the principle of judicial stability, which prevents courts of concurrent jurisdiction from interfering with each other’s proceedings to ensure an orderly and consistent application of the law.

When Courts Collide: Examining Jurisdictional Boundaries in Property Disputes

This case revolves around a land dispute concerning Lot No. 7-B in Talamban, Cebu City, originally owned by Leonora Yngles. After Leonora’s death, the property was inherited by her children and eventually subdivided. A critical juncture occurred when Remedios Cabello, claiming ownership through inheritance, successfully petitioned for reconstitution of the title to Lot No. 7-B after alleging its loss in a fire. Based on this reconstituted title, Remedios sold a portion of the land, Lot No. 7-B1, to spouses Francisco and Margarita Robles, who in turn sold it to spouses Alfonso and Georgia Royo Adlawan (the petitioner). However, the respondents, descendants of Leonora Yngles, contested the validity of Remedios’s title, leading to a legal battle that questioned the very foundation of land ownership and the limits of judicial authority.

The respondents initiated a complaint in RTC Branch 17, Cebu City, seeking to annul Remedios’s title and subsequent transfers, alleging misrepresentation during the reconstitution process. The RTC initially dismissed the case due to the respondents’ failure to prosecute, but later reinstated it after a petition for relief from judgment. Subsequently, the spouses Adlawan were impleaded as additional defendants. The RTC Branch 17 eventually ruled in favor of the respondents, declaring Remedios’s reconstituted title and all derivative titles void. This decision was then appealed to the Court of Appeals (CA). The CA affirmed the RTC’s decision, emphasizing that no Transfer Certificate of Title (TCT) was ever issued to Remedios from which the reconstitution proceedings could be based. Furthermore, the CA held that the spouses Adlawan were not innocent purchasers for value because they bought the subject lot before title was reconstituted.

The core issue before the Supreme Court was whether RTC Branch 17 had the authority to annul the decision of RTC Branch 14, a court of equal jurisdiction, which had ordered the reconstitution of Remedios’s title. Section 9(2) of Batas Pambansa (B.P.) Blg. 129, as amended, explicitly vests in the Court of Appeals exclusive original jurisdiction over actions to annul judgments of the Regional Trial Courts. This provision reflects the doctrine of non-interference or judicial stability, which prevents a court from interfering with the judgments of a court of equal jurisdiction. The purpose is to maintain order and prevent conflicting decisions within the judicial system. The Court emphasized this doctrine, stating:

“The doctrine of non-interference or judicial stability dictates that a trial court has no authority to interfere with the proceedings of a court of equal jurisdiction, much less to annul the final judgment of a co-equal court.”

The Court found that RTC Branch 17 overstepped its authority by effectively nullifying the decision of RTC Branch 14. The Supreme Court then addressed the CA’s ruling that the petitioner was estopped from questioning the RTC’s jurisdiction because the issue was raised for the first time on appeal. The Court disagreed, reiterating the fundamental principle that jurisdiction is conferred by law, and a judgment rendered without jurisdiction is void and without effect. As the Court has stated, “[t]his rule applies even if the issue on jurisdiction was raised for the first time on appeal or even after final judgment.”

The Court distinguished the case from Tijam v. Sibonghanoy, a landmark case where estoppel was applied to prevent a party from belatedly challenging a court’s jurisdiction. In Sibonghanoy, the party invoking lack of jurisdiction had actively participated in the proceedings for fifteen years and only raised the issue after an adverse decision. In contrast, the petitioner in this case raised the jurisdictional issue in their appeal brief to the CA, before the appellate court rendered its decision. Furthermore, the petitioner and her husband were merely impleaded as additional defendants and did not obtain any affirmative relief from the RTC whose jurisdiction they were challenging. Therefore, the Court found that the circumstances did not warrant the application of estoppel by laches, which requires a showing of inequity or unfairness in permitting a right or claim to be enforced.

The Supreme Court reversed the CA’s decision, declaring the RTC Branch 17’s decision null and void for lack of jurisdiction. This ruling underscores the importance of adhering to jurisdictional boundaries within the Philippine judicial system. It reaffirms that only the Court of Appeals has the authority to annul judgments of the Regional Trial Courts, safeguarding the principle of judicial stability and preventing potential chaos in the administration of justice.

This case serves as a critical reminder of the limits of judicial authority and the importance of raising jurisdictional challenges promptly. It clarifies that while estoppel may bar a party from questioning jurisdiction in certain circumstances, the exception is narrowly construed and only applies where there is a clear showing of inequity or unfairness. The Supreme Court’s decision protects the integrity of the judicial system and ensures that judgments are not undermined by courts of equal jurisdiction. It also provides guidance on when a party may be deemed to have waived their right to challenge jurisdiction, emphasizing the need for timely and consistent objections.

FAQs

What was the key issue in this case?	The main issue was whether a Regional Trial Court (RTC) had the jurisdiction to annul the decision of another RTC of equal standing.
What is the doctrine of judicial stability?	The doctrine of judicial stability prevents a court from interfering with the judgments of a court of equal jurisdiction. This promotes order and consistency in the legal system.
Why did the Supreme Court reverse the Court of Appeals’ decision?	The Supreme Court reversed the decision because the RTC that annulled the title acted without jurisdiction, violating the principle of judicial stability.
What is estoppel by laches?	Estoppel by laches prevents a party from raising a jurisdictional issue if they have unduly delayed and actively participated in the proceedings. This doctrine was not applicable in this case.
What was the Tijam v. Sibonghanoy case about?	Tijam v. Sibonghanoy established an exception to the rule that jurisdiction can be raised at any time. It held that a party could be estopped from questioning jurisdiction after long participation.
When can a party question a court’s jurisdiction?	Generally, a party can question a court’s jurisdiction at any stage of the proceedings, even on appeal, because jurisdiction is conferred by law.
Who has the authority to annul judgments of the Regional Trial Courts?	The Court of Appeals has the exclusive original jurisdiction to annul judgments of the Regional Trial Courts, as stated in Batas Pambansa Blg. 129.
What was the effect of the RTC’s void judgment?	The void judgment of the RTC, due to lack of jurisdiction, is considered to have no legal effect. Therefore, it cannot create any rights or obligations.
What does this case mean for property disputes?	This case underscores the importance of jurisdictional boundaries and seeking annulment of judgments from the correct court, which is the Court of Appeals for RTC decisions.

This case highlights the crucial role of jurisdictional integrity in the Philippine legal system. The Supreme Court’s decision ensures that the principle of judicial stability is upheld, preventing courts of equal jurisdiction from interfering with each other’s judgments. This promotes an orderly and consistent application of the law, safeguarding the integrity of the judicial process.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: Georgia Royo Adlawan v. Nicetas I. Joaquino, G.R. No. 203152, June 20, 2016