SUBJECT: CIVPRO Jurisdiction over Subject Matter

Rudolf Lietz Holdings Inc. vs ROD

Paranaque
(GR 133240, Nov 15 2000)
FACTS:
1. RUDOLF LIETZ INC. amended its Articles
of Incorporation to change its name to
RUDOLF LIETZ HOLDINGS.
2. As a consequence, RUDOLF LIETZ filed for
a petition for amendment of the TCTs over
its real properties with the RTCPARANAQUE.
3. However, the RTC dismissed the petition
motu proprio on the ground of improper
venue. Hence, this petition.
4. OSG argued that the RTC did NOT acquire
jurisdiction over the res because it
appeared from the original petition that
the lands are situated in PASAY; hence,
outside the jurisdiction of the RTCPARANQUE.
5. However, RUDOLF LIETZ insisted that RTC
had jurisdiction over the petition for the
amendment of its titles.
ISSUE:
W/N the RTC has jurisdiction over the case.
HELD: YES, RTC has jurisdiciton.
- The jurisdiction of the RTC over matters
involving the registration of lands and
lands registered under the Torrens System
is conferred by SEC. 2, PD 1529 (Property
Registration Decree).
o Nature
of
registration
proceedings; jurisdiction of courts.
Judicial proceedings for the
registration of lands throughout
the Philippines shall be in rem and
shall be based on the generally
accepted principles underlying the
Torrens system.
CFI
(now
RTC)
shall
have
exclusive jurisdiction over all
applications
for
original
registration of title to lands,

including improvements and

interest therein, and over all
petitions filed after original
registration of title, with power
to hear and determine all
questions arising upon such
applications or petitions. XXX
More
specifically,
jurisdiction
over
petitions for amendments of certificates
of title is provided for by SEC. 108, PD
1529:
o Amendment and alteration of
certificates. XXX A registered
owner or other person having
an
interest
in
registered
property, XXX may apply by
petition to the court upon the
ground XXX that the name of
any person on the certificate
has been changed.
PRINCIPLE: The court may only dismiss an
action motu proprio in case of lack of
jurisdiction over the subject matter, litis
pendentia, res judicata, and prescription.

Other issues:
- NO IMPROPER VENUE. The lands are
located in PARANAQUE City as stated on
the faces of the titles. RUDOLF LIETZ thus
correctly filed the petition in the place
where the lands are situated. Hence, the
RTC erred in dismissing the case motu
proprio on the ground of improper venue.
-

When RUDOLF LIETZ initially impleaded

ROD-PASAY as respondent, it did so under
the mistaken belief that the latter was
still the custodian of the TCTs. Thus, the
amended petition was justified and was
promptly done upon knowledge that RODPARANAQUE already took over the record
and custody of the TCTs.