BILAG v. AY-AY

Bernadette S. Bilag, Erlinda Bilag Santillan, Dixon Bilag, Reynaldo B. Suello Heirs of Lourdes S. Bilag, Heirs of Leticia Bilag-Hanaoka, and heirs of Nellie Bilag vs. Estela Ay-Ay, Andres Acop Jr., Felicitas Ap-Ap, Sergio Ap-Ap, John Napoleon A. Ramirez Jr., and Ma. Teresa A. Ramirez

G.R. No. 189950

April 24, 2017

Facts:

The instant case stemmed from a complaint for quieting of title with prayer for preliminary injunction filed by respondents against the petitioners before the RTC Br. 61. Essentially, respondents alleged that petitioner’s predecessors-in-interest sold to them separately various portions of a 159, 496 square meter parcel of land designated by the Bureau of Lands situated at Sitio Benin, Baguio City, and they registered the corresponding Deeds of sale with the Register of Deeds of Baguio City. 

Respondents further alleged that they have been in continuous possession of the said lands since 1976 when they were delivered to them and that they have already introduced various improvements thereon. Petitioners refused to honor the forgoing sales and continued to harass and threatened to demolish their improvements. Petitioners filed a motion to dismiss on the grounds of lack of jurisdiction, prescription/laches/estoppel, and res judicata. The RTC ruled in favour of petitioner, ordered the dismissal of civil case No. 5881-R and dismissing the earlier filed civil case No. 3934-R where respondents similarly sought to be declared the owners of the subject property. Respondents appealed to the CA, the CA then set aside the dismissal of the civil case and remanded the case to the court a quo for trial. The CA concluded that while these cases may involve the same properties, the nature of the action differs; hence, res judicata is not a bar to the present suit. The CA pointed out that in view of respondent’s allegation that they have been in possession of the subject property since 1976, their action to quiet title is imprescriptible.

Issue:

Whether or not the CA gravely erred in setting aside the dismissal of the Civil Case No. 5881-R on the ground of lack of jurisdiction on the part of the RTC?

Held:

Yes. On the issue of jurisdiction, a review of the records shows that the subject property form part of a 159,496 square meter parcel of land designated by Bureau of Lands situated at Sitio Benin, Baguio City. Such parcel of land forms part of the Baguio Town site Reservation, a portion of which was awarded to Iloc Bilag. RTC Br. 61 has no jurisdiction over Civil Case No. 5881-R as the plaintiffs therein seek to quiet title over lands which belong to the public domain. It should be stressed that the court a qou’s lack of subject matter jurisdiction over the case renders it without authority and necessarily obviates the resolution of the merits of the case. To reiterate, when a court has no jurisdiction over the subject matter, the only power it has is to dismiss the action, as any act it performs without jurisdiction is null and void, and without any binding legal effects.