Title Bilag vs.
Ay-ay
Case G.R. No. 189950
Decision Date
Apr 24, 2017
Dispute over 159,496 sqm Baguio land; RTC dismissed quieting of title case, citing lack of jurisdiction
over public land. SC upheld dismissal, ruling jurisdiction lies with Director of Lands.
Facts:
Background of the Case
The case originated from a Complaint for Quieting of Title with Prayer for Preliminary Injunction filed
by respondents (Estela Ay-Ay, Andres Acop, Jr., Felicitas Ap-Ap, Sergio Ap-Ap, John Napoleon A.
Ramirez, Jr., and Ma. Teresa A. Ramirez) against petitioners (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) before the Regional Trial Court (RTC) of Baguio City, Branch 61. The dispute involved
a 159,496-square meter parcel of land in Sitio Benin, Baguio City, designated as Approved Plan No.
544367, Psu 189147.
Respondents' Claims
Respondents alleged that Iloc Bilag, petitioners' predecessor-in-interest, sold various portions of the land
to them through Deeds of Sale, which were registered with the Register of Deeds of Baguio City. They
claimed that Iloc Bilag acknowledged full payment and guaranteed that his heirs would honor the sales.
Respondents further asserted that they had been in continuous possession of the land since 1976 and
had introduced improvements. However, petitioners refused to recognize the sales and allegedly
harassed respondents, prompting the filing of the complaint to quiet title and remove the cloud on their
ownership.
Petitioners' Defense
Petitioners filed a Motion to Dismiss on three grounds:
1. Lack of Jurisdiction: They argued that the land was untitled, unregistered, and part of the
Baguio Townsite Reservation, making it public land. Thus, the RTC lacked jurisdiction, and the
Land Management Bureau should resolve ownership issues.
2. Prescription/Laches/Estoppel: They contended that respondents waited over 27 years to
enforce the Deeds of Sale, making the action barred by prescription or laches.
3. Res Judicata: Petitioners pointed out that respondents had previously filed a similar case (Civil
Case No. 3934-R) in 1998, which was dismissed for lack of merit. The dismissal was affirmed by
the Court of Appeals (CA) and became final, barring the current action.
RTC Ruling
The RTC dismissed the case, agreeing with petitioners on all three grounds:
1. It lacked jurisdiction over the untitled public land.
2. The Deeds of Sale did not confer title, and respondents failed to assert ownership for 27 years.
3. The case was barred by res judicata due to the final dismissal of Civil Case No. 3934-R.
CA Ruling
The CA reversed the RTC's dismissal, holding that:
1. Res Judicata did not apply because the previous case (Civil Case No. 3934-R) was an action for
injunction, while the current case was for quieting of title.
2. The action to quiet title was imprescriptible since respondents had been in possession since
1976.
Issue:
The primary issue before the Supreme Court was whether the CA correctly set aside the dismissal of Civil
Case No. 5881-R and remanded the case for trial.
Ruling:
The Supreme Court granted the petition and reinstated the RTC's dismissal of the case. It held that:
1. The RTC lacked jurisdiction over the case because the subject land was part of the Baguio
Townsite Reservation and remained public land. The authority to determine ownership of
public lands lies with the Director of Lands, not the RTC.
2. The CA erred in not addressing the jurisdictional issue, which was a threshold matter. Any
judgment rendered without jurisdiction is null and void.
3. The Court did not need to address the other grounds (res judicata and prescription/laches) since
the lack of jurisdiction was dispositive.
Ratio:
1. Jurisdiction Over Public Lands: The RTC has no jurisdiction over untitled and unregistered
public lands. The Director of Lands has the exclusive authority to determine ownership and
disposition of such lands.
2. Nullity of Judgment Without Jurisdiction: A court's lack of jurisdiction renders its
actions void and without legal effect. The RTC correctly dismissed the case for lack of
jurisdiction.
3. Res Judicata and Prescription: While the CA addressed these issues, they were rendered moot
by the jurisdictional defect. The Court emphasized that jurisdictional issues must be resolved first
before addressing other grounds.
Conclusion:
The Supreme Court reversed the CA's decision and dismissed Civil Case No. 5881-R for lack of
jurisdiction. The RTC had no authority to hear the case because the subject land was public land, and
jurisdiction over such matters lies with the Director of Lands.
