GEORGIA ROYO ADLAWAN v. NICETAS I. JOAQUINO concurrent jurisdiction.

concurrent jurisdiction. Hence, the RTC Branch 17, Cebu City, as a co-equal court, has no
GR No. 203152, June 20, 2016
BRION, J.:
FACTS:
In 1983, Remedios, niece of the herein petitioner, caused the reconstitution of the title of Lot No.
7-B, a land she claimed to have acquired from her mother, Vicenta. RTC Branch 14, Cebu City,
granted Remedios's petition. Subsequently, Lot No. 7-B was divided into four parcels of land (i.e.,
Lot Nos. 7-B1, 7-B2, 7-B3, and 7-B4), which were issued separate TCTs. Remedios sold Lot No. 7-B1
to spouses Francisco and Margarita Robles (spouses Robles). In 1987, the herein petitioner filed a
complaint to annul Remedios's title and the titles issued therefrom in Branch 17, Cebu City. Lis
pendens was the annotated on the titles. In July 1992, RTC B17 dismissed the respondents'
complaint for annulment of title for their failure to prosecute the case. Consequently, after the
decision became final, annotations of lis pendens was cancelled.
Respondents filed a petition for relief from judgment and the court reinstated their complaint for
annulment of title.RTC granted. By this time, the land was already dold to Sps. Adlawan. Remedios
and Sps Robles moved for reconsideration of the decision to grant relief from judgement to
respondent. RTC denied. On appeal, CA also denied. Ultimately, the SC denied the appeal and such
decision became final in 1993.
In 1994, respondent subsequently impleaded Sps. Adlawan as additional defendants in the
annulment of title case. In 2005, RTC declare null and void the reconstitution of Remedios’ title
and titles issued therefrom. Remedio, Sps. Robles and Sps. Adlawan appealed to CA. The CA
affirmed RTC's decision. It also ruled the B17 can annul the order of reconstitution by B14 bacause
appellants were already estopped to question RTC's jurisfiction for the first time on appeal and
after losing the case for 20 years. As to Sps. Adlawan, CA found that they were not buyers in GF as
they bought the land prior to its reconstitution and that they should have investigated more the lis
pendens annotated in the title. Adlawan elevated the case to SC.
jurisdiction to annul the reconstitution of title previously ordered by the RTC, Branch 14, Cebu City.
(2) No. There is no rule in procedural law as basic as the principle that jurisdiction is conferred by
law, and any judgment, order, or resolution issued without it is void and cannot be given any
effect. The rule to be followed is that the lack of a court’s jurisdiction is a non-waivable defense
that a party can raise at any stage of the proceedings in a case, even on appeal;
The case of Tijam v Sibonghanoy, which laid down the exception to the principle, is not applicable
in the present case. There is no sufficient justification to apply the exception of estoppel by laches.
Petitioner raised the lack of jusrisdiction of RTC on her appeal before the CA decide the case. Also,
it does not involve a situation where a party who, after obtaining affirmative relief from the court,
later on turned around to assail the jurisdiction of the same court that granted such relief by
reason of an unfavorable judgment. The petitioner and her husband did not obtain affirmative
relief from the court whose jurisdiction they are assailing, as they never won their case in the
proceedings below.
(3) Yes. The petitioner and her husband were merely impleaded as additional defendants in the
reinstated complaint for annulment of title – a case originally between the respondents and the
defendants Remedios and the spouses Robles. The original annulment of title case was filed by
the respondents in 1987. The RTC had dismissed the case for failure to prosecute in 1992 but the
complaint was later reinstated after a petition for relief from judgment was successfully filed by
the respondents. The petitioner and her husband were impleaded as defendants in the case only
in 1994. The fact that the petitioner and her husband were not privy to the cases originally filed
before the two RTCs (i.e., Branches 14 and 17, Cebu City), coupled with their claim of good faith,
convinced the court that the petitioner is not guilty of laches despite belatedly raising the
question of jurisdiction only thirteen (13) years later, or in 2007, in their appeal brief to the CA.

ISSUE(S):

(1) WON the RTC Branch 17 has jurisdiction over a court of the same level
(2) WON petitioners were estopped from questioning jurisdiction of Branch 17
(3) WON the Adlawans were buyers in good faith

HELD:

(1) No. Section 9 (2) of Batas Pambansa (B.P.) Blg. 129,16 as amended, vests in the Court of
Appeals, the exclusive original jurisdiction over actions to annul judgments of the Regional Trial
Courts. Also, in accordance with the “doctrine of non-interference or judicial stability”, a judgment
of a court of competent jurisdiction may not be opened, modified, or vacated by any court of