BILAG vs. AY-AY

BILAG vs. AY-AY

BERNADETTE S. BILAG, ERLINDA BILAGSANTILLAN, DIXON BILAG, REYNALDO B. SUELLO, HEIRS OF LOURDES S. BILAG, HEIRS OF LETICIA BILAG-HANAOKA, and HEIRS OF NELLIE BILAG, Petitioners,
vs.
ESTELA AY-AY, ANDRES ACOP, JR., FELICITAS AP-AP, SERGIO AP-AP, JOHN NAPOLEON A. RAMIREZ, JR., and MA. TERESA A. RAMIREZ, Respondents

G.R. NO. 189950
April 24, 2017

DOCTRINE:

The trial court has no jurisdiction over an action for quieting of title involving a land belonging to the public domain for it is the land management bureau which is vested with authority to determine issues of ownership over unregistered public lands.

FACTS:

Respondent Estela Ay-ay filed a complaint for Quieting of Title with Prayer for Preliminary Injunction against petitioner Bernadette Bilag, alleging that the latter’s predecessor-in-interest, Iloc Bilag, sold to them separately various portions of a parcel of land designated by the Bureau of Lands as part of the Baguio Town site Reservation which was awarded to him in a Civil Registration Case. According to respondents, Iloc Bilag caused the subject lands to be removed from the Ancestral Land Claims. When petitioner refused to honor the sale by asserting their adverse rights on the subject lands, respondent was prompted to file the complaint for quieting of title.

For their part, petitioners filed a Motion to Dismiss on the ground of lack of jurisdiction, among others, arguing that it is the Land Management Bureau which has jurisdiction over the case. Petitioner contends that P.D. 1271 expressly declared that all awards, orders and decisions issued by the CFI in the proceedings for the reopening of the civil registration case, covering lands within the Baguio Town site Reservation are null and void and since the subject lands remained unregistered and untitled, it must be classified as lands of public domain.

The RTC ruled in petitioner’s favor and ordered the dismissal of the civil case. On appeal, the CA set aside the dismissal and held that the civil case was an action to quiet title where respondents specifically prayed for the removal of the cloud upon their ownership and possession of the subject lands.

ISSUE:

Whether or not the RTC correctly dismissed the civil case for quieting of title involving untitled and unregistered public lands for lack of jurisdiction.

HELD:

YES. The RTC correctly dismissed the civil case for quieting of title involving untitled and unregistered public because it has no jurisdiction over the subject matter. P.D. 1271 expressly declared as null and void all orders and decisions of the CFI of Baguio in the proceedings for the reopening of the Civil Registration Case covering lands within the Baguio Town site Reservation. Likewise, P.D. 1271 requires, among others, that a Certificate of Title be issued on such lands on or before July 31, 1973. The records reveal that the subject lands are unregistered and untitled, as petitioner’s assertion to that effect was not disputed by respondent.

In view of the foregoing, it is only reasonable to conclude that the subject lands should be properly classified as lands of the public domain. Therefore, since the subject lands are untitled and unregistered public lands, the Director of Lands has the authority to award their ownership. Thus, the RTC correctly recognized its lack of power or authority to hear and resolve respondent’s action for quieting of title. 

It should be stressed that the court’s lack of jurisdiction over the case renders it without authority and necessarily obviates the resolution of the merits of the case. When a court has no jurisdiction over the subject matter, the only power it has is to dismiss the action, as any act it performs without jurisdiction is null and void and without any binding legal effects.