Andaya v.

Abadia et al
This is an appeal praying for the reversal of the orders of the RTC Q.C. Maintaining that the RTC and not the
SEChas jurisdiction over his complaint, petitioner argues that the court a quo should not have dismissed Civil Case
filed by himagainst the respondents.. He asserts that the complaint is based not so much on plaintiff's attempted
removal but rather onthe manner of his removal and the consequent effects thereof.
Facts:
Before the RTC of Q.C., Andaya filed an action for Injunction and Damages with Restraining Orders and/or
PreliminaryInjunction against Abadia et al, alleging that the latter acting in concerts and pursuant to an illegal and
nefarious scheme tooust petitioner from his then positions as President and General Manager of the AFPSLAI, with
grave abuse of authority andin gross and deliberate violation of the norms of human relations and of petitioner's
right to due process, illegally,maliciously and with evident bad faith, convened a meeting of the AFPSLAI Board of
Directors and illegally reorganized themanagement of AFPSLAI by ousting and removing, without just and lawful
cause, petitioner from his positions therein,causing petitioner moral and exemplary damages.The Court ruled that it
has no jurisdiction on corporate matters. Hence this appeal
Issue:
Whether
the RTC and not the SEC has jurisdiction over the petitioners complaint
Ruling:
The allegations against herein respondents in the amended complaint unquestionably reveal intra-corporate
controversiescleverly concealed, although unsuccessfully, by use of civil law terms and phrases. The amended
complaint impleads hereinrespondents who, in their capacity as directors of AFPSLAI, allegedly convened an illegal
meeting and voted for thereorganization of management resulting in petitioner's ouster as corporate officer. While it
may be said that the samecorporate acts also give rise to civil liability for damages, it does not follow that the case is
necessarily taken out of the jurisdiction of the SEC as it may award damages which can be considered consequential
in the exercise of its adjudicativepowers. Besides, incidental issues that properly fall within the authority of a
tribunal may also be considered by it to avoidmultiplicity of actions. Consequently, in intra-corporate matters such
as those affecting the corporation, its directors,trustees, officers, shareholders, the issue of consequential damages
may just as well be resolved and adjudicated by theSEC.Moreover, mere allegations of violation of the provisions of
the Civil Code on human relations do not necessarily call for theapplication of the provisions of the Civil Code in
place of AFPSLAI By-Laws.

Antipolo v. Zapanta [G.R. No. 65334. December 26, 1984.]

First Division, Melencio-Herrera (J): 4 concurring, 1 took no part.
Facts:
The Municipality of ANTIPOLO, for more than 50 years now, has considered the disputed
property,
described below, to be public land subject to ANTIPOLOs use and permission to use within the
prerogatives
and purposes of a municipal corporation. There is indication to the effect that it had been the
site of the public
market as far back as 1908, or at the latest, since 1920 up to today. Gradually, additional
public structures
were built thereon, like the Puericulture and Family Planning Center, the Integrated National
Police Building,
the Office of the Municipal Treasurer, and the public abattoir. Those public structures occupy
almost the
entire area of the land.
On 8 August 1977, a single application for the registration of two distinct parcels of land was
filed by two
distinct applicants before the then CFI Rizal, Branch XV, Makati (the Registration Court). One of
the two

applicants was Conrado Eniceo. He had applied for registration under the Torrens system of a
parcel of land
containing 258 sq. m. The other applicant was Heirs of Joaquin Avendao, and the land they
were applying
for registration was a parcel containing 9,826 sq. m. (the disputed property) surveyed in the
name of the
Municipality of Antipolo. Both parcels were situated in the Municipality of Antipolo. The
application were
approved by the Registration Court on 26 February 1980. ANTIPOLO took steps to interpose an
appeal but
because it failed to amend the Record on Appeal, its appeal was disallowed.
On 22 May 1981, ANTIPOLO filed a complaint (Civil Case 41353) of the CFI Rizal, Branch XIII,
Pasig
against named Heirs of Joaquin Avendao, and their assignees praying for nullification of the
judgment
rendered by the Registration Court. The defendants, in their Answer, pleaded a special defense
of res judicata.
After a preliminary hearing on the mentioned special defense, the case was dismissed.
ANTIPOLO perfected
an appeal to the then Court of Appeals. A notice to file Brief was issued by the Appellate Court,
which
ANTIPOLO claimed it had not received. Upon motion of the Avendano heirs to dismiss on the
ground the
ANTIPOLO had not filed its Brief within the reglementary period, the appeal was dismissed on
23 August
1983 despite the fact that before the dismissal, ANTIPOLO had submitted its Appellants Brief.
ANTIPOLO
filed a motion for reconsideration, which the Appellate Court denied on 27 September 1983 for
lack of legal
and factual basis. Hence, the petition for review on certiorari.
The Supreme Court (1) set aside the resolutions of the appellate court (now IAC) dated 23
August 1983 and
27 September 1983; (2) set aside the judgment of the CFI Rizal in Civil Case 41353 and
rendered the
judgment and decree of the CFI Rizal in LRC N-9995, LRC Record N-52176 null and void in
respect of the
Heirs of Joaquin Avendano; (3) ordered the Register of Deed of Rizal to cancel all certificates
issued by
virtue of decree issued in LRC N-9995, LRC Rec. N-52176 in respect of the Heirs of Isabela
Avendano;
and (4) declared the certificate of title issuied in the name of Conrado Eniceo, and transfers
therefrom as
decreed in LRC N-995, LRC Rec. N-52176 to continue to be valid; without pronouncements as
to costs.
1.
Technicality yields to broader interests of substantial justice; When jurisdiction is questioned
Although failure to file Brief within the time provided by the Rules is, indeed, a ground for
dismissal
of an appeal, this Court had held that rules of technicality must yield to the broader interests of
substantial

justice specially where, as in this case, the important issue of lack of jurisdiction over the subject
matter of the
Land Registration Court has been raised.
2.
Remand is ordinarily the appropriate relief; Court resolves merits due to 3 motions for early
decision filed
Property, 2003 (
9
)
Haystacks (Berne Guerrero)

A remand to the lower Court, for the entertainment of the appeal on the merits, would ordinarily
be
the appropriate relief. However, considering the three Motions for Early Decision filed by private
respondents, we shall resolve the substantive merits of the appeal to the appellate tribunal from
the judgment
rendered in the case.
3.
Disputed property devoted to public use and public service; Possession does not presuppose
ownership; Lands presumed to be public lands unless contrary is proven; Tax declaration mere
indicia
of a claim to ownership
At the time the application for registration was filed on 8 August 1977, the disputed property was
already devoted to public use and public service. Therefore, it was outside the commerce of
man and could no
longer be subject to private registration. The claim of the Avendano heirs that they merely
tolerated
occupancy by ANTIPOLO which had borrowed the disputed property from them, since they had
been in
possession, since as far back as 1916, erroneously presupposes ownership thereof since that
time. They forget
that all lands are presumed to be public lands until the contrary is established. The fact that the
disputed
property may have been declared for taxation purposes in their names or of their predecessorsin-interest as
early as 1918 does not necessarily prove ownership. They are merely indicia of a claim of
ownership.
ANTIPOLO had also declared the disputed property as its own in Tax Declarations 909, 993 and
454.
4.
Res judicata does not apply since Land Registration Court had no jurisdiction to entertain the
registration of public property
Since the Land Registration Court had no jurisdiction to entertain the application for registration
of
public property of ANTIPOLO, its Decision adjudicating the disputed property as of private
ownership is null
and void. It never attained finality, and can be attacked at any time. It was not a bar to the action
brought by
ANTIPOLO for its annulment by reason of res judicata.
5.
Effects of decision which is null and void by virtue of lack of jurisdiction

The want of jurisdiction by a court over the subject-matter renders the judgment void and a
mere
nullity, and considering that a void judgment is in legal effect no judgment, by which no rights
are divested,
from which no rights can be obtained, which neither binds nor bars any one, and under which all
acts
performed and all claims flowing out of are void, and considering, further, that the decision, for
want of
jurisdiction of the court, is not a decision in contemplation of law, and hence, can never become
executory, it
follows that such a void judgment cannot constitute a bar to another case by reason of res
judicata.
6.
Titles null and void; Cancellation pursued through ordinary action
When the titles issued by a Court, or by virtue of the decision or decree of the court, with no
jurisdiction over the subject matter; such are to be held to be null and void and perforce, they
must be ordered
cancelled. It follows that if a person obtains a title under the Public Land Act which includes, by
oversight,
lands which cannot be registered under the Torrens System, or when the Director of Lands did
not have
jurisdiction over the same because it is a public forest, the grantee does not, by virtue of the
said certificate of
title alone, become the owner of the land illegally included
(Republic vs. Animas, 56 SCRA 499, 503;
Ledesma vs. Municipality of Iloilo, 49 Phi. 769)
. Under these circumstances, the certificate of title may be
ordered cancelled and the cancellation may be pursued through an ordinary action therefor.
This action cannot
be barred by the prior judgment of the land registration court, since the said court had no
jurisdiction over the
subject matter. And if there was no such jurisdiction, then the principle of res judicata does not
apply.