Natividad Aragon v.

CA and the Manila Banking Corporation

GR No. 124333, March 26, 1997
Facts: Marenir Development Corporation obtained P4M loan from MBC, secured by REM over 4 lots. Marenir sold 1 lot to
Aragon for P132k, P20k DP and P1,745 monthly installment. Aragon completed payment, but Marenir was unable to
transfer TCT to his name so Aragon filed a complaint for specific performance and damages against Marenir in RTC QC.
(Civil Case # 1)
1989, RTC ordered Marenir to execute DoAS, and deliver oweners copy of TCT and actual physical possession. No
appeal was taken by Marenir so Aragon filed a Motion to Direct Branch Clerk of Court or Deputy Sheriff to Execute
Absolute DoAS. The Registry of Deeds QC refused to register the land unless the owners duplicate TCT was presented.
MBC agreed to give the owners duplicate TCT for P185. Aragon: gago nagbayad na kaya ako ng P192k akin na yan!
Aragon filed a complaint for delivery of title and damages against MBC before RTC QC. (Civil Case # 2)
RTC: in favor of Aragon. MBC to deliver owners duplicate title of TCT
CA: in favor of MBC, dismissed complaint. In the case vs. Marenir, shouldve filed with HLURB. RTC has no jurisdiction so
the decision is NAV.
Issue: WoN CA acquired jurisdiction over the case
Held: No. CA took cognizance of Aragon v. Marenir case. (Civil Case #1) The parties are different. That was not appealed
to the CA and no action to annul judgment of RTC. CA committed error when it declared NAV the proceedings in Civil
Case # 1.
BP 129, sec. 9 vests in the CA exclusive appellate jurisdiction over all final decisions and orders of RTC.
Only refers to cases appealed to it from the RTC from which the case originated. Like any other court, it is
necessary that the CA must have jurisdiction over the subject matter, the parties, the issues and the res before it
can validly decide any case submitted to it. Hence, it cannot acquire appellate jurisdiction over any case not
properly brought to it by the parties concerned.
Jurisdiction over the subject matter of a case may be objected to at any stage of the proceeding even on appeal, this
particular rule means that jurisdictional issues in a case can be raised only during the proceedings in said case and during
the appeal of said case. It certainly does not mean that lack of jurisdiction of a court in a case may be raised during the
proceedings of another case, in another court and even by anybody at all. Certainly, we cannot countenance this
procedure as this will lead to absurdity and is against the basic principle of jurisdiction.
CA reversed and set aside. RTC reinstated.