City of Dumaguete vs Philippine Ports Authority (Poala S.
August 24, 2011| LEONARDO-DE CASTRO, J. | G.R. No. 168973
FACTS:
The City of Dumaguete filed an application for original registration of title
over a parcel of land.
The City of Dumaguete claimed ownership and continuous possession of the
land for more than 30 years.
The Republic of the Philippines and the Philippine Ports Authority opposed
the application, arguing that the land is a foreshore land and therefore not
registerable.
The Regional Trial Court (RTC) initially dismissed the application for lack
of jurisdiction.
The RTC later set aside its order and decided to proceed with a full-blown
trial to determine the factual issues.
The Philippine Ports Authority filed a petition for certiorari and prohibition
with the Court of Appeals.
The Court of Appeals granted the petition and set aside the RTC orders.
The City of Dumaguete filed a petition for review with the Supreme Court.
ISSUE:
Whether the RTC has jurisdiction over the subject matter
RULING:
- The Supreme Court held that the RTC did not commit grave abuse of
discretion in setting aside the order of dismissal and allowing for a full-
blown proceeding.
- The Court emphasized that procedural rules should be liberally applied to
ensure justice and that the RTC should have the opportunity to determine the
factual issues in the case.
- The Court clarified that jurisdiction over the subject matter of the case is
determined by the allegations in the complaint, and the RTC had jurisdiction
over the application for registration
Batas Pambansa Blg. 129, otherwise known as The Judiciary Reorganization Act of 1980,
created the RTC 35 in place of the CFI. Presently, jurisdiction over an application for land
registration remains with the RTC where the land is situated, except when such jurisdiction is
delegated by the Supreme Court to the Metropolitan Trial Court, Municipal Trial Courts, and
Municipal Circuit Trial Courts under certain circumstances.
Firmly entrenched is the principle that jurisdiction over the subject matter is conferred by law.
Consequently, the proper CFI (now the RTC) under Section 14 of PD 1529 (Property
Registration Decree) has jurisdiction over applications for registration of title to land.
The court emphasized that while the applicant (City of Dumaguete) bears the burden of proving
that the subject property is private and capable of registration, the RTC has the authority to
determine whether the land applied for is registerable and can be confirmed. However, if the
subject matter of the application is found to be inalienable public land, the RTC has no
jurisdiction to order the registration of the land and must dismiss the application.
