UP Law F2021 14 Aragon v. CA and Manila Banking Corp.

Civil Procedure Jurisdiction 1997 Hermosisima, Jr., J.

SUMMARY

Marenir Devt. Corp. obtained a loan from MBC. which was secured by an REM over 4 lots. Marenir later sold
one of these lots to Aragon. Marenir however was unable to transfer TCT to Aragon’s name, prompting
Aragon to file a compliant against Marenir (Case 1). RTC ordered Marenir to execute a DoAS and deliver TCT
and actual possession. No appeal was taken. The RD-QC however refused to register the land unless the TCT
was presented. MBC agreed to present the TCT after Aragon paid them. Aragon refused and filed a
complaint against MBC (Case 2). RTC ruled for Aragon but was reversed by CA, saying RTC has no
jurisdiction. SC ruled that CA erred in its judgment as it took cognizance of Case 1, as it was only Case 2
which was appealed to them.

FACTS

 Marenir Development Corporation obtained a P4M loan from Manila Banking Corp. (MBC), secured
by a Real Estate Mortgage over 4 lots. Marenir sold 1 lot to Aragon for P132k (Terms: P20k
Downpayment and P1,745 monthly installments). Aragon completed payment, but Marenir was
unable to transfer TCT to her name so Aragon filed a complaint for specific performance and
damages against Marenir in the RTC QC. (Civil Case 1 – Aragon v. Marenir)

 In 1989, RTC ordered Marenir to execute a Deed of Absolute Sale, and deliver owner’s copy of TCT
and actual physical possession. No appeal was taken by Marenir so Aragon filed a Motion to Direct
Branch Clerk of Court or Deputy Sheriff to Execute Absolute Deed of Sale.

 The Registry of Deeds QC refused to register the land unless the owner’s duplicate TCT was
presented. MBC agreed to surrender the owner’s duplicate TCT provided that Aragon pay them
P185k. Aragon refused, claiming that she had already paid P192k.

 Aragon thus filed a complaint for delivery of title and damages against MBC before RTC QC.
(Civil Case 2 – Aragon v. MBC)

 RTC: for Aragon. MBC to deliver owner’s duplicate title of TCT. MBC appealed to CA.

 CA: for MBC. Dismissed complaint. The case against Marenir (Civil Case 1), should have been filed
with the HLURB. RTC has no jurisdiction so the decision is null and void.

RATIO

W/N the CA acquired jurisdiction over the case.

No. The CA took cognizance of Aragon v. Marenir (Civil Case 1). The parties are different. That was not
appealed to the CA and no action to annul judgment of RTC. CA committed error when it declared null and
void the proceedings in Civil Case 1 as it was not the case appealed before it.

BP 129, sec. 9 vests in the CA exclusive appellate jurisdiction over all final decisions and orders of RTC.
 Only refers to cases appealed to it from the RTC from which the case originated. Like any other court,
it is necessary that the CA must have jurisdiction over the subject matter, the parties, the issues and
the res before it can validly decide any case submitted to it. Hence, it cannot acquire appellate
jurisdiction over any case not properly brought to it by the parties concerned.

While jurisdiction over the subject matter of a case may be objected to at any stage of the proceeding even
on appeal, this particular rule, however, means that jurisdictional issues in a case can be raised only during
the proceedings in said case and during the appeal of said case. It certainly does not mean that lack of
jurisdiction of a court in a case may be raised during the proceedings of another case, in another court and
even by anybody at all. Certainly, this procedure cannot be countenanced as this will lead to absurdity and
is against the basic principle of jurisdiction.

FALLO

WHEREFORE, the decision of the respondent Court of Appeals is REVERSED and SET ASIDE, and the
decision of the Regional Trial Court dated January 31, 1994 is REINSTATED, with costs against private
respondents.

SO ORDERED.