G.R. No.

192975

November 12, 2012

REPUBLIC OF THE PHILIPPINES, represented by the Regional Executive Director of the Department
of Environment and Natural Resources, Regional Office No. 3, Petitioner,
vs.
ROMAN CATHOLIC ARCHBISHOP OF MANILA, Respondent.
The Facts
petitioner Republic filed a complaint before the RTC of Malolos City, Bulacan, for cancellation of titles and
reversion against respondent RCAM and several others.6The complaint alleged, inter alia, that RCAM appears as
the registered owner of eight (8) parcels of land, supposedly issued by the Register of Deeds of Bulacan in favor
of RCAM. A reading, however, of the said decision reveals that it only refers to certain lots. RCAM sold the said
eight (8) parcels of land to the other named defendants in the complaint resulting in the cancellation of OCT and
issuance of transfer certificates of title in the names of the corresponding transferees. Subsequently, the Lands
Management Bureau conducted an investigation and ascertained that the subject lots were certified by the Bureau
of Forest Development as falling within the unclassified lands of the public domain and it was only on later that
they were declared alienable and disposable with no public land application/ land patent.7
petitioner Republic received a copy of a motion for leave to intervene and to admit complaint-in-intervention
filed by the Samahang Kabuhayang San Lorenzo KKK, Inc. (KKK),8occupants of the subject property, which
was subsequently granted by the RTC.9
During the course of the pre-trial, RCAM filed a motion to dismiss assailing the jurisdiction10 of the RTC over
the complaint. It alleged that the action for reversion of title was essentially one for annulment of judgment of the
then Court of First Instance (CFI) of Bulacan, acting as a Land Registration Court,11 hence, beyond the
competence of the RTC to act upon.
Ruling of the Trial Court
the RTC denied RCAM's motion to dismiss for being premature. Hence, it found a need to first ascertain the
litigious issues of whether a separate prior decision was promulgated and whether the issuance of the subject
decree and inclusion specific lots were done in violation of such separate decision. RCAM's motion for
reconsideration having been denied, the matter was elevated to the CA on certiorari alleging grave abuse of
discretion on the part of the RTC.
Ruling of the Court of Appeals
the CA held that while reversion suits are allowed under the law, the same should be instituted before the CA
because the RTC cannot nullify a decision rendered by a co-equal land registration court. The CA further applied
equitable estoppel against the State and considered it barred from filing a reversion suit. It explained that the lots
were already alienated to innocent purchasers for value and the State failed to take action to contest the title for
an unreasonable length of time. Hence, the CA ordered the RTC to grant RCAM's motion to dismiss. Both
petitioners separately moved for reconsideration which the CA denied
Issue Before the Court
The consolidated cases raise the common issue of whether or not the RTC has jurisdiction over the action
filed by the Republic.
The Courts Ruling

The petitions are meritorious.

Respondent's motion to dismiss assails the jurisdiction of the RTC over the nature of the action before it. It is
axiomatic that the nature of an action and whether the tribunal has jurisdiction over such action are to be
determined from the material allegations of the complaint, the law in force at the time the complaint is filed, and
the character of the relief sought irrespective of whether the plaintiff is entitled to all or some of the claims
averred.20 Jurisdiction is not affected by the pleas or the theories set up by defendant in an answer to the
complaint or a motion to dismiss the same.21
In the present case, the material averments, as well as the character of the relief prayed for by petitioners in the
complaint before the RTC, show that their action is one for cancellation of titles and reversion, not for annulment
of judgment of the RTC.phi1
The RTC may properly take cognizance of reversion suits which do not call for an annulment of judgment of the
RTC22 acting as a Land Registration Court. Actions for cancellation of title and reversion, like the present case,
belong to the class of cases that "involve the title to, or possession of, real property, or any interest therein"23 and
where the assessed value of the property exceeds P20,000.00,24 fall under the jurisdiction of the
RTC.25Consequently, no grave abuse of discretion excess of jurisdiction can be attributed to the RTC in denying
RCAMs motion to dismiss.1wphi1
Moreover, it should be stressed that the only incident before the CA for resolution was the propriety of RCAMs
motion to dismiss, thus, it was premature for the CA at this stage to apply the doctrine of equitable estoppel as
the parties have not presented any evidence that would support such finding.
WHEREFORE, the petitions are GRANTED.

G.R. No. 174077

November 21, 2012

ELLICE AGRO-INDUSTRIAL CORPORATION, represented by its Chairman of the Board of Directors

and President, RAUL E. GALA, Petitioner,
vs.
RODEL T. YOUNG, DELFIN CHAN, JIM WEE, and GUIA G. DOMINGO, *** Respondents.
The Facts
On July 24, 1995, Rodel T. Young, Delfin Chan and Jim Wee (respondents) and Ellice Agro-Industrial
Corporation (EAIC), represented by its alleged corporate secretary and attorney-in-fact, Guia G. Domingo
(Domingo) entered into a Contract to Sell, under certain terms and conditions, wherein EAIC agreed to sell to the
respondents a parcel of land and registered under EAICs name Pursuant to the Contract to Sell,3 respondents
paid EAIC, partial payment for the acquisition of the subject property. Despite such payment, EAIC failed to
deliver to respondents the owners duplicate certificate of title of the subject property and the corresponding deed
of sale as required under the Contract to Sell. Prompted by the failure of EAIC to comply with its obligation,
respondents had their Affidavit of Adverse Claim and a Complaint5 for specific performance, against EAIC
before the RTC.
The initial attempt to serve the summons and a copy of the complaint and its annexes on EAIC, was unsuccessful
as EAIC could not be located. Another attempt was made to serve the alias summons on EAIC through the
residence of Domingo was, this time, successful.As a result of EAICs failure to appear in the scheduled pre-trial
conference, the RTC rendered Decision ordering EAIC to deliver the owners duplicate copy of TCT and to

execute a final deed of sale in favor of respondents.

Subsequently, EAIC filed its Petition for Relief from Judgment of the RTC Decision premised on the alleged
fraud committed by Domingo in concealing the existence of both the Contract to Sell and a Civil Case from
EAIC. The RTC denied the petition for relief from judgment for being clearly filed out of time.
EAIC initiated the Petition for Annulment of Judgment of the RTC Decision before the CA grounded on the
RTCs lack of jurisdiction over EAIC and the extrinsic fraud committed by Domingo. EAIC discarded any
knowledge of the said sale and the suit filed by respondents against it. According to EAIC, Domingo was not its
President, Manager, Secretary, Cashier, Agent or Director at the time the summons was served upon her and she
did not possess the requisite authorization to represent EAIC in the subject transaction.
In its Reply filed before the CA, EAIC explained that the RTC did not touch upon the issue of fraud in the
petition for relief from judgment as it was dismissed for being filed out of time. In its Decision, the CA dismissed
the petition for annulment of judgment. In its decision, the CA stated that It would serve no useful purpose then
to delve into the issues of jurisdiction and fraud raised in the petition as the petition itself is unavailing under the
circumstances.
EAICs motion for reconsideration was denied by the CA. Hence, this petition for review.
The Issues
The main issue for the Courts consideration is whether the RTC validly acquired jurisdiction over the
person of EAIC,
The Courts Ruling
The Court finds merit in the petition.
It is a settled rule that jurisdiction over the defendant is acquired either upon a valid service of summons or the
defendants voluntary appearance in court. Without such, any judgment of the court which has no jurisdiction
over the person of the defendant is null and void. The requirements of the rule on summons must be strictly
followed, otherwise, the trial court will not acquire jurisdiction over the defendant. Service of summons on
anyone other than the president, manager, secretary, cashier, agent, or director, is not valid.
In the present case, the pertinent document showing EAICs composition at the time the summons was served
upon it reveal that Domingo was not its president, manager, secretary, cashier, agent or director. In view of
Domingos lack of authority to properly represent EAIC, the Court is constrained to rule that there was no valid
service of summons binding on it.
The RTC failed to validly acquire jurisdiction over EAIC and cannot likewise subscribe to respondents argument
that by filing its answer with counterclaim, through Domingo, with the RTC, EAIC is deemed to have voluntarily
submitted itself to the jurisdiction of the RTC.
In this case, Undoubtedly, Domingo lacked the necessary authority to bind EAIC before the RTC despite the
filing of an Answer with Counterclaim. EAIC cannot be bound or deemed to have voluntarily appeared before
the RTC by the act of an unauthorized stranger.
In view of the fact that EAIC was not validly served with summons and did not voluntarily appear, the RTC did
not validly acquire jurisdiction over the person of EAIC. Consequently, the proceedings had before the RTC and
ultimately its November 11, 1999 Decision were null and void.1wphi1

Pursuant to the Rules of Court, a judgment of annulment shall set aside the questioned judgment or final order or
resolution and render the same null and void.
WHEREFORE, the petition is GRANTED.