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BERNADETTE S. BILAG v. ESTELA AY-AY

FACTS:

The respondents filed a complaint for Quieting of Title against the petitioners before the RTC, claiming that they purchased portions of a parcel of land from the petitioners' predecessor-in-interest and have been in continuous possession since 1976. The petitioners filed a Motion to Dismiss on several grounds, including lack of jurisdiction, prescription/laches/estoppel, and res judicata. The RTC granted the motion and dismissed the case, citing lack of authority, failure to perfect title, and res judicata. The respondents appealed to the CA, which reversed the dismissal and remanded the case for trial before the RTC. The petitioners then filed a petition for review with the Supreme Court, challenging the CA's ruling.

ISSUES:

  1. Whether or not the Regional Trial Court of Baguio City, Branch 61, has jurisdiction to hear Civil Case No. 5881-R

  2. Whether or not the dismissal of Civil Case No. 5881-R due to the inapplicability of res judicata, prescription, or laches is correct.

RULING:

  1. Jurisdiction The Supreme Court ruled that the RTC Br. 61 lacks jurisdiction to hear Civil Case No. 5881-R because the subject lands are part of the Baguio Townsite Reservation and are considered public lands. Therefore, the authority to determine ownership of such lands lies with the Director of Lands and not the RTC. Consequently, Civil Case No. 5881-R is dismissed for lack of jurisdiction.

  2. Res judicata, prescription, or laches Given the lack of jurisdiction, the Court found it unnecessary to address the other grounds related to res judicata, prescription, or laches.

PRINCIPLES:

  1. Jurisdiction Over Subject Matter Jurisdiction is the power and authority of a court to hear, try, and decide a case. It is conferred by law and not by any agreement between the parties or the court's belief.

  2. Public Lands Lands classified as public lands, such as those within the Baguio Townsite Reservation, are under the administrative jurisdiction of the Director of Lands, who is responsible for determining ownership and disposition.

  3. Void Judgments A judgment rendered by a court without jurisdiction is null and void, creates no rights, and produces no effects. It can be attacked at any time.

  4. PD 1271 All orders and decisions issued by the Court of First Instance of Baguio and Benguet in connection with the reopening of Civil Reservation Case No. 1 are null and void unless validated through the issuance of a Certificate of Title by July 31, 1973.

  5. Action for Quieting Title An action to quiet title requires that the plaintiff have a legal or equitable title to the property and that there is a cloud on their title due to an instrument, record, deed, claim, encumbrance, or proceeding that is asserted to be invalid.