Primary Holding
An action for annulment of judgment under Rule 47 of the Rules of Court is unavailable against judgments of quasi-judicial bodies such as the SEC, because Rule 47 expressly limits its application to judgments of regional trial courts and municipal trial courts, and neither the RTC nor the CA has jurisdiction over such an action absent an express statutory grant. A quasi-judicial body such as the SEC commits grave abuse of discretion amounting to excess of jurisdiction when it adjudicates on the validity of a sale to a third party and orders the cancellation of a Torrens title—matters requiring the application of general civil and property laws outside its specialized competence—rendering its decision void and all acts emanating from it without legal effect.
Background
Rene H. Imperial and Julian C. Napal organized NIDSLAND Resources and Development Corporation to engage in real estate business, with Napal contributing land and Imperial assuming Napal's financial obligations. Alfonso B. Cruz, Jr. entered the picture as a purchaser of a portion of the property Napal had committed to convey to NIDSLAND. At the time relevant to the dispute, the Securities and Exchange Commission exercised quasi-judicial power over intra-corporate controversies under Presidential Decree No. 902-A, and the delineation between the SEC's jurisdiction and that of regular courts turned on both the relationship of the parties and the nature of the controversy. The Torrens system of land registration, governed by Presidential Decree No. 1529, provided that certificates of title are generally indefeasible and may not be collaterally attacked.
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SEC, Nov. 10, 1998 — Hearing Officer Gonzales rendered a Decision declaring the Deed of Absolute Sale between Napal and Cruz void ab initio, ordering cancellation of Cruz's TCT and directing Napal to convey the Subject Property to NIDSLAND.
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SEC Decision became final and executory, enforced Jan. 13, 1999 — A Deed of Conveyance was issued transferring the Subject Property to NIDSLAND; TCT No. 43936 (Cruz) was cancelled and TCT No. 49730 (NIDSLAND) issued on Jan. 19, 1999.
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CA, Aug. 31, 1999 — Dismissed Napal's Petition for Annulment of Judgment under Rule 47 (CA-G.R. SP No. 51258), holding that Rule 47 is not available to annul SEC judgments and that the proper remedy is certiorari and prohibition; entry of judgment made Nov. 16, 2000.
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RTC Legazpi City, Branch 4 (Judge Consulta), Jan. 22, 2001 — Cruz filed an "RTC Petition" to nullify the SEC Decision (Civil Case No. SR-09); dismissed motu proprio for lack of jurisdiction over the SEC.
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CA, Oct. 28, 2002 (CA-G.R. SP No. 65720) — Held RTC acted with grave abuse of discretion in dismissing the Petition and ordered remand and due course.
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RTC Legazpi City, Branch 4 (Judge Armes), Sept. 21 and Nov. 23, 2006 — Denied Imperial and NIDSLAND's Omnibus Motion and Supplemental Motion seeking dismissal of the RTC Petition on jurisdictional and prescription grounds.
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CA, Mar. 6 and July 3, 2007 (CA-G.R. SP No. 97823) — Dismissed Imperial and NIDSLAND's Petition for Certiorari and Prohibition assailing Judge Armes' Orders, and denied reconsideration.
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RTC Legazpi City, Branch 4 (Judge Armes), Mar. 24, 2009 — Rendered RTC Main Decision declaring portions of the SEC Decision null and void, annulling the Deed of Conveyance and NIDSLAND's titles, and ordering restoration of Cruz's TCT No. 43936.
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CA, Sept. 13, 2010 — Reversed the RTC Main Decision and dismissed Civil Case No. 10325.
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Supreme Court, Jan. 30, 2017 — Reversed the CA resolutions in G.R. No. 178842 and the CA decision in G.R. No. 195509; declared the SEC Decision void and nullified the Deed of Conveyance.
Facts
On September 24, 1993, Julian C. Napal and Rene H. Imperial entered into a Memorandum of Agreement to organize NIDSLAND Resources and Development Corporation for the purpose of engaging in the real estate business. Under the agreement, Napal undertook to convey to NIDSLAND a tract of land consisting of four lots covered by Transfer Certificate of Title (TCT) Nos. 37737, 37738, 37739, and 21026, and to convey to Imperial a two-hectare portion of the same property situated in Taysan, Legazpi City. The parties intended to develop the land into a subdivision. Imperial, for his part, committed to settle Napal's obligation to the Rural Bank of Ligao, Inc., which was about to foreclose its mortgage on the property; pay Napal's tax liabilities to the Bureau of Internal Revenue, which encumbered the largest portion of the property with a tax lien; fund NIDSLAND's initial operating capital; and provide for Napal's personal drawings in an amount not exceeding ₱1,200,000. Imperial faithfully complied with his obligations, but Napal failed to convey a certain portion of the property, in particular Lot 15-C covered by TCT No. 21026, referred to as the Subject Property.
On July 24, 1996, Napal sold the Subject Property to Alfonso B. Cruz, Jr., as evidenced by a Deed of Absolute Sale. While the deed bore the date July 24, 1996, the sale was registered with the Registry of Deeds of Legazpi City only on August 27, 1996. Because Napal continued to refuse to convey the Subject Property to NIDSLAND, Imperial filed on July 30, 1996 — after the sale to Cruz but before its registration — a derivative suit before the Securities and Exchange Commission (SEC), docketed as SEC LEO Case No. 96-0004. On the same day, Imperial also filed a notice of lis pendens with the Registry of Deeds, which was annotated on TCT No. 21026 as Entry No. 99956/99957. Since the annotation occurred after the sale to Cruz but before its registration, the notice of lis pendens was carried over to the new TCT No. 43936 issued in Cruz's name. The SEC Case proceeded without the participation of Cruz, who held the new TCT covering the Subject Property during the continuation of the hearings. On August 8, 1997, while the SEC Case was pending, Imperial and NIDSLAND also filed an action for annulment of sale against Cruz before the RTC of Legazpi City, docketed as Civil Case No. 9419. The RTC dismissed the action on August 14, 1997, holding that it should have been filed in the original case where the decree of registration was entered, and the CA later affirmed this dismissal.
On November 10, 1998, SEC Hearing Officer Santer G. Gonzales rendered a Decision in favor of Imperial and NIDSLAND, declaring the Deed of Absolute Sale between Napal and Cruz void ab initio on the finding that the sale was simulated and intentionally antedated to appear perfected prior to the filing of the notice of lis pendens. The SEC ordered the cancellation of the TCT in Cruz's name, directed Napal to execute a deed of conveyance of the Subject Property in favor of NIDSLAND, and mandated Napal to deliver possession to NIDSLAND. Because Napal did not appeal, the SEC Decision became final and executory and was enforced on January 13, 1999. A Deed of Conveyance was issued on that date, TCT No. 43936 in Cruz's name was cancelled, and a new TCT No. 49730 was issued in NIDSLAND's name on January 19, 1999.
On February 18, 1999, Napal filed with the CA a Petition for Annulment of Judgment under Rule 47 (CA-G.R. SP No. 51258), seeking to nullify the SEC Decision on the ground that the SEC lacked jurisdiction because the case did not involve an intra-corporate controversy. On April 15, 1999, Cruz filed a Motion to Join as Party-Petitioner, claiming to be a transferee pendente lite of the Subject Property. The CA dismissed the petition on August 31, 1999, explaining that Rule 47 is not available to annul SEC judgments and that the proper remedy is a special civil action for certiorari and prohibition. No party appealed, and entry of judgment was made on November 16, 2000. On January 22, 2001, Cruz filed a pleading denominated as a "Petition" before the RTC of Legazpi City seeking to nullify the SEC Decision, docketed as Civil Case No. SR-09. Presiding Judge Gregorio A. Consulta dismissed the petition motu proprio on the ground that RTCs have no jurisdiction over the SEC. Cruz elevated the case to the CA, which held on October 28, 2002 that the RTC acted with grave abuse of discretion and ordered the case remanded and given due course. The petition was re-docketed as Civil Case No. 10325 and reraffled, first to Branch 3 (Judge Henry B. Basilla) and then, after Judge Basilla voluntarily inhibited himself, to Branch 4 (Respondent Judge Edgar L. Armes). During the proceedings, Imperial and NIDSLAND repeatedly sought dismissal on jurisdictional grounds, filing an Omnibus Motion on August 22, 2006 and a Supplemental Motion on September 7, 2006, raising arguments on the failure to state material dates, the lack of showing that no appeal or other plain remedy was available, the filing beyond the 60-day reglementary period under Rule 65, and the binding effect of the SEC Decision on Cruz as a successor-in-interest pendente lite. Judge Armes denied these motions on September 21 and November 23, 2006, holding that the issues had been settled by the CA and that an action to declare the nullity of a void judgment does not prescribe. The RTC eventually rendered its Main Decision on March 24, 2009, declaring portions of the SEC Decision null and void, annulling the Deed of Conveyance and the titles issued to NIDSLAND, and ordering the restoration of Cruz's TCT No. 43936. The CA reversed this decision on September 13, 2010, and dismissed Civil Case No. 10325. Both sets of parties then elevated the matter to the Supreme Court through the two consolidated petitions.
Arguments of the Petitioners
- Timeliness and Reglementary Period (G.R. No. 178842 — Imperial and NIDSLAND): Imperial and NIDSLAND argued that the CA erred in affirming the RTC's allowance of the RTC Petition, which was filed three and a half years after the finality of the SEC Decision and two years and three months from the time Cruz received notice of its promulgation, far beyond the 60-day reglementary period for a special civil action for certiorari under Rule 65. They stressed that neither the CA nor Cruz presented any compelling reason for the relaxation of the reglementary period.
- Material Dates and Adequate Remedy (G.R. No. 178842 — Imperial and NIDSLAND): Imperial and NIDSLAND contended that Cruz failed to state the required material dates in his initiatory petition and failed to show that there was no appeal or any other plain, speedy, and adequate remedy available against the SEC Decision.
- Binding Effect of SEC Decision (G.R. No. 178842 — Imperial and NIDSLAND): Imperial and NIDSLAND argued that the SEC Decision, having become final and fully executed, was binding against Cruz as a successor-in-interest pendente lite to Napal's title over the Subject Property, pursuant to Section 19 of Rule 3 of the Rules of Court.
- Status as Registered Owner and Indispensable Party (G.R. No. 195509 — Cruz): Cruz claimed that he is the registered owner of the Subject Property and was thus an indispensable party to the SEC Case who should have been impleaded. Since the SEC Case was a personal action and he was never impleaded, the SEC never acquired jurisdiction over him, and any judgment obtained by Imperial and NIDSLAND has no binding effect on him.
- Invalidity of the Deed of Conveyance (G.R. No. 195509 — Cruz): Cruz argued that since the property was already registered in his name, any deed of conveyance Napal executed pursuant to the SEC Decision transferred no rights because Napal no longer had rights over the Subject Property at that time.
- No Estoppel (G.R. No. 195509 — Cruz): Cruz contended that the CA erred in holding he was estopped from challenging the cancellation of his TCT. He explained that he could not have participated in the SEC Case to protect his rights because it pertained to an intra-corporate dispute and he was not a stockholder of NIDSLAND. He also emphasized that Imperial and NIDSLAND never prayed for the cancellation of his TCT in the SEC Case, giving him no reason to intervene until the SEC ruled against his title. Cruz further argued that he could not have filed a separate action because Imperial and NIDSLAND had already filed the Annulment of Sale Action against him before the RTC, and filing another case while that was pending would have amounted to multiplicity of suits.
Arguments of the Respondents
- Prior CA Adjudication of Jurisdiction (G.R. No. 178842 — Cruz and Judge Armes): Respondent Judge Armes maintained that the jurisdictional issues had already been settled by the CA in the certiorari case filed by Cruz, where the CA ruled that the RTC had jurisdiction and directed it to give due course to the RTC Petition. Judge Armes held that this directive was unqualified and unconditional.
- Imprescriptibility of Action to Declare Nullity (G.R. No. 178842 — Cruz and Judge Armes): Cruz and Judge Armes argued that an action to declare the nullity of a void judgment does not prescribe, placing it beyond the ambit of the 60-day reglementary period under Section 4, Rule 65 of the Rules of Court. They further contended that since Cruz was never a party in the SEC Case, he was never officially notified of the SEC Decision, and the 60-day period — which contemplates official notice from the deciding authority — was inapplicable.
- Reversal of RTC Main Decision (G.R. No. 195509 — Imperial and NIDSLAND): Imperial and NIDSLAND, as respondents in the second petition, relied on the CA's September 13, 2010 Decision, which reversed the RTC Main Decision and dismissed Civil Case No. 10325. The specific arguments they advanced as respondents in G.R. No. 195509 are not separately recounted in the decision text beyond their reliance on the CA's ruling.
Issues
- Jurisdiction over Annulment of SEC Judgment: Whether the RTC of Legazpi City has jurisdiction to declare the nullity of the SEC Decision.
- Nature of the RTC Petition: Whether the RTC Petition filed by Cruz is an action for annulment of judgment under Rule 47 or a special civil action for certiorari under Rule 65.
- Validity of the SEC Decision: Whether the SEC Decision was rendered with grave abuse of discretion amounting to excess of jurisdiction in annulling the sale to Cruz and ordering the cancellation of his TCT.
- Effect on Torrens Titles: Whether the certificates of title issued to NIDSLAND pursuant to the void SEC Decision may be cancelled in these proceedings.
Ruling
- Jurisdiction over Annulment of SEC Judgment: No. The RTC Petition should have been dismissed for lack of jurisdiction, as neither the RTC nor the CA possesses jurisdiction over an action for annulment of judgment against a decision of the SEC under Rule 47, which expressly applies only to judgments of regional trial courts and municipal trial courts.
- Nature of the RTC Petition: The RTC Petition is an action for annulment of judgment on the ground of lack of jurisdiction over the person under Rule 47, not a special civil action for certiorari under Rule 65, as determined by its material allegations and the relief prayed for.
- Validity of the SEC Decision: The SEC Decision is void, having been rendered with grave abuse of discretion amounting to excess of jurisdiction, because the SEC overstepped its intra-corporate jurisdiction by annulling a sale to a third party and ordering the cancellation of a Torrens title—matters requiring the application of general civil and property laws outside the SEC's specialized competence.
- Effect on Torrens Titles: The certificates of title issued to NIDSLAND cannot be directly cancelled in these proceedings, notwithstanding their derivation from a void judgment, because the indefeasibility of a Torrens title and rules on jurisdiction prohibit the Court from doing so; the proper party may file a petition for cancellation of title before the trial court with jurisdiction over the matter.
Ruling Rationale
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Jurisdiction over Annulment of SEC Judgment: The Court traced the evolution of jurisprudence on the availability of annulment of judgment against quasi-judicial bodies. Prior to BP 129, the Court in BF Northwest Homeowners Association, Inc. vs. Intermediate Appellate Court held that RTCs could annul judgments of quasi-judicial bodies of the same rank as courts of first instance. With the passage of BP 129, Section 9(a) vested the CA with jurisdiction over annulment of judgments of RTCs only, and Section 9(3) provided for the CA's appellate jurisdiction over quasi-judicial bodies. The 1997 Rules of Civil Procedure, through Rule 47, expressly limited annulment of judgment to judgments of RTCs and MTCs. In Cole vs. Court of Appeals, the Court held that the CA has no jurisdiction over a petition for annulment of judgment under Rule 47 against a decision of the HLURB. This was reiterated in Elcee Farms, Inc. vs. Semillano (NLRC) and Galang vs. Court of Appeals (SEC). In Springfield Development Corporation, Inc. vs. Presiding Judge, RTC, Misamis Oriental, Br. 40, the Court ruled that neither the RTC nor the CA has jurisdiction over annulment of judgment of quasi-judicial bodies, emphasizing that the silence of BP 129 on the CA's jurisdiction to annul judgments of quasi-judicial bodies indicates lack of such authority. In Macalalag vs. Ombudsman, the Court clarified that annulment of judgment, like appeal, is a statutory right that exists only when expressly granted by law. Applying these principles, the Court found no law at the time pertinent to the case that allowed the filing of a petition for annulment of judgment before the RTC or the CA to set aside a void judgment of the SEC on the ground of lack of jurisdiction. This holding pertains only to cases filed prior to RA 8799, which transferred jurisdiction over intra-corporate disputes to RTCs designated as commercial courts, as to which Rule 47 clearly applies.
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Nature of the RTC Petition: The nature of an action is determined by the material allegations in the complaint and the type of relief prayed for. The RTC Petition's core allegation was that the SEC declared the sale between Napal and Cruz void without impleading Cruz, and that the SEC had no power to order the transfer of title from Cruz to NIDSLAND because Cruz was never heard. Cruz prayed that the SEC Decision be declared null and void. These allegations capture the elements of a petition for annulment of judgment on the ground of lack of jurisdiction over the person under Rule 47. The RTC Petition made no allegations that the SEC Decision was rendered with grave abuse of discretion, and thus cannot be treated as a special civil action for certiorari under Rule 65. Since the RTC Petition is an action for annulment of judgment, and this remedy is unavailable against SEC decisions, the RTC Petition cannot prosper.
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Validity of the SEC Decision: Under Section 5 of PD 902-A, the SEC's original and exclusive jurisdiction extended to intra-corporate controversies. The Court applied two interrelated tests: the relationship test (whether any of the enumerated intra-corporate relationships exist between the parties) and the controversy test (whether the dispute is intrinsically connected with the regulation of the corporation). The Court traced the development from the relationship test in Union Glass & Container Corporation vs. Securities and Exchange Commission and Abejo vs. De la Cruz, through the refinement in Viray vs. Court of Appeals and Lozano vs. De los Santos, which added the controversy test requiring that the dispute be intrinsically connected with the regulation of the corporation. Applying both tests, the Court found that the SEC lacked jurisdiction to order the cancellation of the sale between Napal and Cruz. Assailing the validity of the sale involves the application of the law on sales, which, as held in Intestate Estate of Alexander T. Ty vs. Court of Appeals, falls within the jurisdiction of ordinary civil courts. The question of whether Cruz's TCT should be cancelled goes into the proper application of PD 1529 and related doctrines, including the indefeasibility of Torrens titles and the effect of a notice of lis pendens—matters outside the SEC's special competence. The SEC also adjudicated on Cruz's rights without giving him the opportunity to be heard, violating due process. Furthermore, the SEC's factual findings were based solely on Imperial's testimony, and the SEC applied the substantial evidence standard rather than preponderance of evidence required for civil actions. The SEC's disregard of established law and jurisprudence on its own jurisdiction, its adjudication on the rights of a non-party, and its cancellation of a Torrens title without due process constituted grave abuse of discretion—defined as the capricious and whimsical exercise of judgment, the exercise of power in an arbitrary manner so patent or gross as to amount to evasion of positive duty.
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Effect on Torrens Titles: A void judgment creates no rights and imposes no duties; any act performed pursuant to it has no legal effect. Thus, the Deed of Conveyance issued pursuant to the void SEC Decision is nullified. However, the certificates of title issued to NIDSLAND, though arising from a void judgment, cannot be directly cancelled in these proceedings. The indefeasibility of a Torrens title prevents such action. As held in Heirs of Spouses Benito Gavina and Juana Euste vs. Court of Appeals, the general rule that the direct result of a void contract cannot be valid is inapplicable when the integrity of the Torrens system is involved; a void certificate of title cannot be cancelled in a proceeding not instituted for that purpose. The Court also lacks jurisdiction over the cancellation of certificates of title, and the nature of the action before it—a petition for review on certiorari of an action for annulment of judgment—bars it from ruling on the certificates of title themselves. The proper party may, however, use this Decision as it definitively settles that the certificates of title issued to NIDSLAND arose from a void judgment and should have no force and effect; this Decision operates as res judicata on that question.
Doctrines
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Nature of a Void Judgment — A void judgment is no judgment at all in legal contemplation. It has no legal or binding effect or efficacy for any purpose or at any place. It cannot affect, impair, or create rights. It is not entitled to enforcement and may be entirely disregarded or declared inoperative by any tribunal in which effect is sought to be given to it. A judgment rendered without jurisdiction, or with grave abuse of discretion amounting to lack or excess of jurisdiction, is void. A void judgment never becomes final and may be resisted in any action or proceeding whenever it is involved. In this case, the SEC Decision was declared void for grave abuse of discretion, rendering the Deed of Conveyance issued pursuant to it null and without legal effect.
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Annulment of Judgment as a Statutory Right — An action for annulment of judgment, like the remedy of appeal, is a statutory right. No party may invoke it unless a law expressly grants the right and identifies the tribunal which has jurisdiction over the action. Rule 47 of the Rules of Court limits annulment of judgment to judgments of regional trial courts and municipal trial courts. Neither the RTC nor the CA has jurisdiction over an action for annulment of judgment against a decision of a quasi-judicial body such as the SEC, absent an express statutory grant. The Court applied this doctrine to hold that the RTC Petition, being an action for annulment of judgment, could not prosper against the SEC Decision.
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Relationship Test and Controversy Test for Intra-Corporate Disputes — The determination of whether the SEC has jurisdiction over a case depends on two interrelated determinants: (1) the status or relationship of the parties (the relationship test), under which the SEC has jurisdiction when the controversy pertains to the relationship between the corporation and the public, the state, its stockholders, or among stockholders themselves; and (2) the nature of the question that is the subject of the controversy (the controversy test), which requires that the dispute be intrinsically connected with the regulation of the corporation. Where the controversy does not call for the use of any technical expertise but the application of general laws, the case is cognizable by ordinary courts. The Court applied both tests to find that the SEC lacked jurisdiction to annul the sale to Cruz and cancel his Torrens title, as these issues involve the law on sales and the Property Registration Decree, not intra-corporate matters.
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Indefeasibility of Torrens Titles — A Torrens certificate of title is conclusive proof of ownership and is generally indefeasible. The law prohibits a collateral attack on a certificate of title. Even when a certificate of title is the direct result of a void judgment, it cannot be cancelled in a proceeding not instituted for that purpose, because the sanctity of the Torrens system must be preserved. The Court applied this doctrine to decline direct cancellation of NIDSLAND's titles, directing instead that the proper party file a petition for cancellation of title before the trial court with jurisdiction over the matter.
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Grave Abuse of Discretion — Grave abuse of discretion is the capricious and whimsical exercise of judgment, the exercise of power in an arbitrary manner. It must be so patent or gross as to amount to the evasion of a positive duty or a virtual refusal to perform a duty enjoined or to act at all in contemplation of law. Grave abuse of discretion exists when the act is done contrary to the Constitution, the law, or jurisprudence, or executed whimsically, capriciously, or arbitrarily out of malice, ill will, or personal bias. The Court found that the SEC committed grave abuse of discretion by disregarding established law on its jurisdictional limits, adjudicating on the rights of a non-party, and cancelling a Torrens title without due process.
Key Excerpts
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"An action for the annulment of a void judgment, like the remedy of appeal, is a statutory right. No party may invoke it unless a law expressly grants the right and identifies the tribunal which has jurisdiction over this action." — This opening passage frames the ratio decidendi of the case, establishing that annulment of judgment is not an inherent right but one that must be expressly granted by law, a principle central to the Court's holding that the RTC Petition could not prosper.
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"While it is correct that both the regional trial courts and the CA cannot take cognizance of a petition for annulment of judgment of a quasi-judicial body under Rule 47 of the Rules of Court, they may nevertheless do so, if a law categorically provides for such a remedy and clearly provides them with jurisdiction." — This passage articulates the nuanced rule that reconciles the unavailability of Rule 47 against quasi-judicial bodies with the possibility of an express statutory grant, a principle frequently cited in subsequent jurisdictional disputes.
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"The establishment of any of the relationships mentioned in Union will not necessarily always confer jurisdiction over the dispute on the SEC to the exclusion of the regular courts. The statement made in one case that the rule admits of no exceptions or distinctions is not that absolute. The better policy in determining which body has jurisdiction over a case would be to consider not only the status or relationship of the parties but also the nature of the question that is the subject of their controversy." — This quotation from Viray vs. Court of Appeals, as adopted by the Court, articulates the controversy test that supplements the relationship test, a canonical formulation in Philippine corporate law jurisdiction.
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"A void judgment is 'a lawless thing, which can be treated as an outlaw and slain at sight, or ignored wherever and whenever it exhibits its head.'" — This quotation from Banco Español-Filipino vs. Palanca, as cited by the Court, provides the classic formulation of the effect of a void judgment, underscoring that all acts emanating from it have no force and effect.
Precedents Cited
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Canero vs. University of the Philippines, G.R. No. 156380, September 8, 2004, 437 SCRA 630 — Cited for the definition of a void judgment as having no legal or binding effect, which the Court applied to declare the SEC Decision void and all acts emanating from it without legal effect.
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Yu vs. Judge Reyes-Carpio, G.R. No. 189207, June 15, 2011, 652 SCRA 341 — Cited for the definition of grave abuse of discretion as a capricious or whimsical exercise of judgment equivalent to lack of jurisdiction, and for the restriction of certiorari to truly extraordinary cases where the act of the lower court is wholly void.
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BF Northwest Homeowners Association, Inc. vs. Intermediate Appellate Court, G.R. No. L-72370, May 29, 1987, 150 SCRA 543 — Cited as the pre-BP 129 ruling establishing that RTCs could annul judgments of quasi-judicial bodies of the same rank, a doctrine later altered by BP 129 and Rule 47.
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Cole vs. Court of Appeals, G.R. No. 137551, December 26, 2000, 348 SCRA 692 — Followed for the proposition that the CA has no jurisdiction over a petition for annulment of judgment under Rule 47 against a decision of a quasi-judicial body (HLURB), a principle extended by analogy to the SEC.
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Galang vs. Court of Appeals, G.R. No. 139448, October 11, 2005, 472 SCRA 259 — Followed for the categorical ruling that the CA has no jurisdiction over annulment of a void judgment rendered by the SEC, as Rule 47 pertains only to judgments of RTCs.
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Springfield Development Corporation, Inc. vs. Presiding Judge, RTC, Misamis Oriental, Br. 40, G.R. No. 142628, February 6, 2007, 514 SCRA 326 — Followed and distinguished as the case that explained neither the RTC nor the CA possesses jurisdiction over annulment of judgment of quasi-judicial bodies, and that the silence of BP 129 on the CA's jurisdiction to annul judgments of quasi-judicial bodies indicates lack of such authority.
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Macalalag vs. Ombudsman, G.R. No. 147995, March 4, 2004, 424 SCRA 741 — Followed for the principle that annulment of judgment is a statutory right that exists only when expressly granted by law, providing the analytical framework for determining whether the remedy is available and before which tribunal.
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Union Glass & Container Corporation vs. Securities and Exchange Commission, G.R. No. L-64013, November 28, 1983, 126 SCRA 31 — Cited as the origin of the relationship test for determining SEC jurisdiction over intra-corporate controversies.
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Viray vs. Court of Appeals, G.R. No. 92481, November 9, 1990, 191 SCRA 308 — Cited as the case that introduced the controversy test, requiring consideration of not only the relationship of the parties but also the nature of the question in controversy, a test the Court applied to find the SEC lacked jurisdiction.
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Intestate Estate of Alexander T. Ty vs. Court of Appeals, G.R. Nos. 112872 & 114672, April 19, 2001, 356 SCRA 661 — Followed for the ruling that the determination of whether a contract is simulated is an issue resolved by applying the Civil Code and is properly cognizable by courts of general jurisdiction, not the SEC.
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Heirs of Spouses Benito Gavina and Juana Euste vs. Court of Appeals, G.R. No. 120154, June 29, 1998, 291 SCRA 495 — Followed for the doctrine that the general rule on the invalidity of the direct result of a void contract is inapplicable when the integrity of the Torrens system is involved, precluding the Court from directly cancelling NIDSLAND's titles.
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Gonzales vs. Solid Cement Corporation, G.R. No. 198423, October 23, 2012, 684 SCRA 344 — Cited for the principle that a void judgment never becomes final and that void judgments are an exception to the rule on immutability of final judgments.
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Banco Español-Filipino vs. Palanca, 37 Phil. 921 (1918) — Cited for the classic formulation that a void judgment is "a lawless thing, which can be treated as an outlaw and slain at sight, or ignored wherever and whenever it exhibits its head."
Provisions
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Section 5, Presidential Decree No. 902-A (Reorganization of the Securities and Exchange Commission) — Vested the SEC with original and exclusive jurisdiction over intra-corporate controversies, including devices or schemes amounting to fraud and misrepresentation detrimental to stockholders, controversies arising out of intra-corporate or partnership relations, and controversies in the election or appointment of directors, officers, or managers. The Court applied this provision to delineate the limits of the SEC's jurisdiction, finding that annulling a sale to a third party and cancelling a Torrens title fell outside its scope.
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Section 9, Batas Pambansa Bilang 129 (The Judiciary Reorganization Act of 1980) — Vested the CA with jurisdiction over annulment of judgments of RTCs under Section 9(a) and appellate jurisdiction over judgments of quasi-judicial bodies under Section 9(3). The Court relied on the absence of any provision granting the CA jurisdiction over annulment of judgments of quasi-judicial bodies to conclude that neither the CA nor the RTC has such jurisdiction.
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Rule 47, Rules of Court (1997 Revised Rules on Civil Procedure) — Provides the remedy of annulment of judgment on the ground of extrinsic fraud and lack of jurisdiction, but expressly limits its application to judgments of regional trial courts and municipal trial courts. The Court applied Rule 47 to determine that the RTC Petition, being an action for annulment of judgment, could not be brought against the SEC Decision.
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Rule 65, Rules of Court — Provides the remedy of a special civil action for certiorari to nullify acts of a tribunal rendered with grave abuse of discretion amounting to lack or excess of jurisdiction. The Court distinguished Rule 65 from Rule 47, finding that the RTC Petition did not allege grave abuse of discretion and thus could not be treated as a certiorari petition.
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Presidential Decree No. 1529 (The Property Registration Decree of 1978) — Governs the Torrens system of land registration. The Court cited PD 1529 and related doctrines on the indefeasibility of Torrens titles to justify its refusal to directly cancel the certificates of title issued to NIDSLAND, directing instead that the proper party file a petition for cancellation of title before the trial court with jurisdiction.
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Section 19, Rule 3, Rules of Court — Provides that a successor-in-interest pendente lite is bound by judgments rendered in the pending action. Imperial and NIDSLAND invoked this provision to argue that the SEC Decision was binding on Cruz, but the Court's holding that the SEC Decision was void rendered this argument moot.
Notable Concurring Opinions
Presbitero J. Velasco, Jr. (Chairperson), Lucas P. Bersamin, Bienvenido L. Reyes, and Alfredo Benjamin S. Caguioa concurred. No separate concurring opinions were issued.