SPRINGFIRELD DEVT CORP. VS. PRESIDING JUDGE, RTC-40, CAGAYAN DE ORO CITY, G.R. NO.

142628, February 6, 2007 Austria-Martinez, J.: FACTS: Springfield Development Corporation, Inc. bought Lot No. 2291-C and Lot No. 2291-D from Petra Capistrano Piit to develop a subdivision project. The Department of Agarian Refrom Adjudication Board declared the nature of the property as residential and not suitable for agriculture ordered the heirs of Piit and Springfield to pay the farmer-beneficiaries therein. Petitioners now seek for annulment of judgment before the RTC then to the Court of Appeals. ISSUE: Whether or not the CA has jurisdiction over actions for annulment of judgments. HELD: YES. With the introduction of B.P. Blg. 129, the rule on annulment of judgments was specifically provided in Section 9(2), which vested in the then Intermediate Appellate Court (now the CA) the exclusive original jurisdiction over actions for annulment of judgments of RTCs. Sec. 9(3) of B.P. Blg. 129 also vested the CA with exclusive appellate jurisdiction over all final judgments, decisions, resolutions, orders, or awards of Regional Trial Courts and quasi-judicial agencies, instrumentalities, boards or commissions, except those falling within the appellate jurisdiction of the Supreme Court in accordance with the Constitution, the provisions of this Act, and of sub-paragraph (1) of the third paragraph and subparagraph (4) of the fourth paragraph of Section 17 of the Judiciary Act of 1948.

SHANGRI-LA INTERNATIONAL HOTEL MANAGEMENT, LTD., SHANGRI-LA PROPERTIES, INC., MAKATI SHANGRI-LA HOTEL & RESORT, INC., AND KUOK PHILIPPINES PROPERTIES, INC vs. DEVELOPERS GROUP OF COMPANIES, INC. G.R. No. 159938 January 22, 2007 GARCIA, J.: FACTS: Developers Group of Companies, Inc. (DGCI) filed a Motion for Reconsideration praying for the reversal of the Supreme Court's Decision of March 31, 2006. In its motion, respondent-movant DGCI raises grounds which is a mere rehash of movants previous arguments. ISSUE: Whether or not the motion for reconsideration must be denied.

HELD: YES. Considering that the grounds presently raised have been sufficiently considered, if not squarely addressed, in the subject Decision, it behooves movant to convince the Court that certain findings or conclusions in the Decision are contrary to law. As it is, however, the motion does not raise any new or substantial legitimate ground or reason to justify the reconsideration sought.

BANCO FILIPINO SAVINGS AND MORTGAGE BANK vs. HON. AMALIK P. ESPINOSA, JR., Presiding Judge, Municipal Trial Court in Iloilo City, Branch 2, and TALA REALTY SERVICES CORPORATION, G.R. No. 162922 January 31, 2007 CARPIO MORALES, J.: FACTS: Tala Realty Services Corporation sought to evict petitioner, Banco Filipino Savings and Mortgage Bank from the premises of its branch offices in nine different locations for nonpayment of rent. In its complaint for ejectment, reaching the Supreme Court, by Decision of June 25, 2001, it ordered petitioner to vacate the subject premises and restore possession thereof to private respondent. Subsequently, private respondent filed with the trial court, the MTC in Iloilo City, Branch 2, a motion for execution of this Courts Decision of June 25, 2001 in G.R. No. 132051. Public respondent, Presiding Judge Espinosa of Branch 2 of the MTC in Iloilo City, granted on even date private respondents Motion for Execution in accordance with this Courts June 25, 2001 Decision, stating that there was nothing more for it to do but to have it fully executed. ISSUE: Whether public respondent acted without or in excess of jurisdiction, or with grave abuse of discretion. HELD: YES. A court, tribunal or administrative agency acts without jurisdiction if it does not have the legal power to determine the case. Where the respondent is clothed with the power to determine the case, it nevertheless acts in excess of jurisdiction when it oversteps its authority as determined by law. Public respondent has the power to rule on a Motion for Execution if the appeal has been duly perfected and finally resolved. Public respondent overstepped his authority, however, when he ordered the execution of this Courts Decision of June 25, 2001, the same not being the final resolution of petitioners appeal.

ROSALINA CLADO-REYES, ALICIAREYES-POTENCIANO, ANTONIO C. REYES, BERNARDO C. REYES, JOVITO C. REYES, MARIA REYES-DIZON, BERNARDA REYES-LLANZA, deceased represented by BONG R. LLANZA and REYNALDO C. REYES (deceased), represented by NINO R. REYES vs. SPOUSES JULIUS and LILY LIMPE G.R. No. 163876, July 9, 2008 QUISUMBING, J.: FACTS: Petitioners filed an action to quiet title, reconveyance and damages against respondents and alleged that they have been occupying the disputed lot since 1945 through their predecessorin-interest, Mamerto B. Reyes. They claimed that during his lifetime, Mamerto had accepted a verbal promise of the former lot owner, Felipe Garcia, to give the disputed lot to him in exchange for the surrender of his tenancy rights as a tiller thereof. Petitioners presented two documents, namely (1) Certification and (2) Pagpapatunay allegedly executed by Simeon I. Garcia, the eldest son of Felipe, attesting to such facts. ISSUE: Whether or not petitioners have a cause of action to quiet title, reconveyance and damages against respondents. HELD: NO. The documentary evidence petitioners presented, namely, the Certification and Pagpapatunay, did not confirm their title over the disputed lot. First, original copies of those documents were not presented in court. Second, Simeon I. Garcia, the declarant in those documents, was not presented in court to prove the veracity of their contents. Third, even a cursory examination of those documents would not show any transfer or intent to transfer title or ownership of the disputed lot. Fourth, petitioners did not bother to adduce evidence that Simeon I. Garcia, as the eldest son of the late Felipe Garcia, inherited the entire lot as to effectively convey title or ownership over the disputed lot, i.e. thru extrajudicial settlement of the estate of the late Felipe Garcia. Accordingly, the documents allegedly executed by Simeon I. Garcia are purely hearsay and have no probative value.

[G.R. No. 147379. February 27, 2002] HEIRS OF AMBROCIO KIONISALA, namely, ANA, ISABEL, GRACE, JOVEN and CARMELO, all surnamed KIONISALA vs. HEIRS OF HONORIO DACUT, namely: VISAMINDA D. OREVILLO, VIOLETA DACUT, JOSEPHINE DACUT and ELIZABETH DACUT BELLOSILLO, J.: FACTS: Private respondents filed a complaint for declaration of nullity of titles, reconveyance and damages against petitioners involving two parcels of land Lot No. 1017 and Lot No. 1015. Said lots were registered in their respective names. They claimed absolute ownership of Lot 1015 and 1017 even prior to the issuance of the corresponding free patents and certificates of title. ISSUE: Whether or not the complaint filed by private respondents was sufficient. HELD: YES. A cause of action for declaration of nullity of free patent and certificate of title would require allegations of the plaintiffs ownership of the contested lot prior to the issuance of such free patent and certificate of title as well as the defendants fraud or mistake; as the case may be, in successfully obtaining these documents of title over the parcel of land claimed by plaintiff. Private respondents allege in their complaint all the facts necessary to seek the nullification of the free patents as well as the certificates of title covering Lot 1015 and Lot1017. Clearly, they are the real parties in interest in light of their allegations that they have always been the owners and possessors of the two (2) parcels of land even prior to the issuance of the documents of title in petitioners favor, hence the latter could only have committed fraud in securing them.

LUCIANO P. PAZ vs. REPUBLIC OF THE PHILIPPINES, ACTING THROUGH THE DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES, PUBLIC ESTATES AUTHORITY, FILINVEST DEVELOPMENT CORPORATION, and FILINVEST ALABANG, INC., G.R. No. 157367, November 23, 2011 BERSAMIN, J.: FACTS: Petitioner brought a petition for the cancellation of Original Certificate of Title (OCT) No. 684 docketed as LRC Case No. 00-059. The petition, ostensibly made under Section 108 of P.D. No. 1529, impleaded the Republic of the Philippines, Filinvest Development Corporation, and Filinvest Alabang, Inc. as respondents. The petition averred that the petitioner was the owner of the land consisted of approximately 14,310 hectares; that OCT No. 684 was registered in the name of the Republic, and included Lot 392 of the Muntinlupa Estate with an area of approximately 244 hectares; that Lot 392 was segregated from OCT No. 684, resulting in the issuance of Transfer Certificate of Title (TCT) No. 185552, also in the name of the Republic; that FDC and FAI developed Lot 392 into a subdivision based on their joint venture agreement with the Government; that pursuant to the joint venture agreement, Lot 392 was further subdivided, causing the cancellation of TCT No. 185552, and the issuance of TCTs for the resulting individual subdivision lots in the names of the Republic and FAI; and that the subdivision lots were then sold to third parties. ISSUE: Whether or not PD 1529 is applicable to the case at bar. HELD: Based on the provision, the proceeding for the amendment and alteration of a certificate of title under Section 108 of P.D. No. 1529 is applicable in seven instances or situations, namely: (a) when registered interests of any description, whether vested, contingent, expectant, or inchoate, have terminated and ceased; (b) when new interests have arisen or been created which do not appear upon the certificate; (c) when any error, omission or mistake was made in entering a certificate or any memorandum thereon or on any duplicate certificate; (d) when the name of any person on the certificate has been changed; (e) when the registered owner has been married, or, registered as married, the marriage has been terminated and no right or interest of heirs or creditors will thereby be affected; (f) when a corporation, which owned registered land and has been dissolved, has not conveyed the same within three years after its dissolution; and (g) when there is reasonable ground for the amendment or alteration of title. In sum,the petitioner was in reality seeking the reconveyance of the property covered by OCT No. 684, not the cancellation of a certificate of title as contemplated by Section 108 of P.D. No. 1529. Thus, his petition did not fall under any of the situations covered by Section 108, and was for that reason rightly dismissed.

BASILIO RIVERA, TOMAS RIVERA, CORNELIO RIVERA and LADISLAO RIVERA vs. THE HONORABLE COURT OF APPEALS, AND SPOUSES DANILO DEATO and DIVINA LEGASPI, G.R. No. 141863, June 26, 2003 CORONA, J.: FACTS: Basilio Rivera, Tomas Rivera, Cornelio Rivera and Ladislao Rivera filed before the Regional Trial Court of Valenzuela, Branch 75, a complaint for quieting of title and ownership with cancellation of title against respondent spouses Danilo and Divina Deato. Petitioners claimed ownership by virtue of acquisitive prescription over Lot 7 of the Malinta Estate, situated in the province of Bulacan. On the other hand, respondent spouses contend that petitioners are the agricultural tenants of Lot 7 of the Malinta Estate whom they agreed to pay disturbance compensation just to vacate the property. Later on, however, petitioners changed their mind and decided to sue respondents, claiming ownership over the said property. ISSUE: Whether or not respondents title to the lot in question should be upheld. HELD: YES. According to petitioners, their previous counsel committed gross negligence in failing to present in evidence Assignment of Sales Certificate No. 668 dated May 25, 1909 which is material to establishing their right of ownership over the subject lot. They contend that said document belonged to their grandmother and served as their title over the subject parcel of land. They allege that during the trial of the case, their former counsel, Atty. Darum, deliberately disregarded said document in favor of his own erroneous theory of the case that their title to the land was based on prescription. Darum overlooked the fact that the said mode of acquiring ownership cannot prevail over titled property as in the case at bar.