SABITSANA vs MUERTEGUI

FACTS:

In 1981 Alberto Garcia executed an unnotarized Deed of Sale in favor of respondent Juanito Muertegui
over a 7,500-square meter parcel of unregistered land. Juanito's father, Domingo Muertegui, Sr., and
brother, Domingo Jr. took actual possession of the lot and planted thereon coconut and ipil-ipil trees.

Then, in 1991, Garcia sold the lot to the Muertegui family lawyer, petitioner Atty. Clemencio C. Sabitsana,
Jr. through a notarized deed of absolute sale.

When Domingo Sr. passed away, his heirs applied for registration and coverage of the lot under the
Public Land Act or Commonwealth Act No. 141. Thereafter, Atty. Sabitsana opposed the application,
claiming that he was the true owner of the lot.

Juanito, through his attorney-in-fact Domingo Jr., filed a case for quieting of title and preliminary
injunction, against herein petitioners Atty. Sabitsana and his wife, Rosario, claiming that they bought the
lot in bad faith and are exercising acts of possession and ownership over the same, which acts thus
constitute a cloud over his title. Petitioner, on the other hand, insisted that the RTC of Naval, Biliran did
not have jurisdiction over the case, which involved title to or interest in a parcel of land the assessed
value of which is merely P1,230.00.

The trial court held that petitioners are not buyers in good faith. Petitioner Atty. Sabitsana was the
Muertegui family’s lawyer, and was informed beforehand by Carmen that her family had purchased the
lot; thus, he knew of the sale to Juanito. After conducting an investigation, he found out that the sale
was not registered. With this information in mind, Atty. Sabitsana went on to purchase the same lot and
raced to register the sale ahead of the Muerteguis, expecting that his purchase and prior registration
would prevail over that of his clients, the Muerteguis.

The CA, through its questioned Decision, denied the appeal and affirmed the trial court's Decision in
toto. It declared that Juanito, as the rightful owner of the lot, possessed the requisite cause of action to
institute the suit for quieting of title and obtain judgment in his favor

ISSUE:

Whether or not the CA erred in holding that the RTC has jurisdiction over the case in view of the fact that
the assessed value of the subject land was only P1,230, and stated market value of only P3,450).

HELD:

The RTC has jurisdiction over the suit for quieting of title.

On the question of jurisdiction, it is clear under the Rules that an action for quieting of title may be
instituted in the RTCs, regardless of the assessed value of the real property in dispute. Under Rule 63 of
the Rules of Court, an action to quiet title to real property or remove clouds therefrom may be brought
in the appropriate RTC.
It must be remembered that the suit for quieting of title was prompted by petitioners' letter-opposition
to respondent's application for registration. Thus, in order to prevent a cloud from being cast upon his
application for a title, respondent filed an action to obtain a declaration of his rights. In this sense, the
action is one for declaratory relief, which properly falls within the jurisdiction of the RTC pursuant to Rule
63 of the Rules of Court.

The sale to respondent Juanito was executed on September 2, 1981 via an unnotarized deed of sale,
while the sale to petitioners was made via a notarized document only on October 17, 1991, or ten years
thereafter. Thus, Juanito who was the first buyer has a better right to the lot, while the subsequent sale
to petitioners is null and void, because when it was made, the seller Garcia was no longer the owner of
the lot.

The fact that the sale to Juanito was not notarized does not alter anything, since the sale between him
and Garcia remains valid nonetheless. Notarization, or the requirement of a public document under the
Civil Code, is only for convenience, and not for validity or enforceability. And because it remained valid as
between Juanito and Garcia, the latter no longer had the right to sell the lot to petitioners, for his
ownership thereof had ceased.

Nor can petitioners' registration of their purchase have any effect on Juanito's rights. The mere
registration of a sale in one's favor does not give him any right over the land if the vendor was no longer
the owner of the land, having previously sold the same to another even if the earlier sale was
unrecorded. Neither could it validate the purchase thereof by petitioners, which is null and void.
Registration does not vest title; it is merely the evidence of such title. Our land registration laws do not
give the holder any better title than what he actually has.

DEPT. OF FINANCE vs DELA CRUZ

FACTS:

The case stemmed from the issuance of Executive Order No. 140 (EO 140) on 2 September 2013, which
created the Customs Policy Research Office (CPRO) in the Department of Finance (DOF)

CPRO "shall be responsible for reviewing the customs administration policies, rules and procedures, and
thereafter providing sound recommendations for the improvement of the same."

Bureau of Customs (BOC) Commissioner Rozzano Rufino B. Biazon issued Customs Personnel Order No.
B-189-2013 (CPO 189-2013) detailing 27 BOC personnel holding the positions of Collector of Customs V
and VI, including respondents in this case, to CPRO "effective immediately and valid until sooner
revoked." CPO 189-2013 was approved by DOF Secretary Cesar V. Purisima (Secretary Purisima).

Respondents filed an action for Declaratory Relief with Application for Temporary Restraining Order
and/or Writ of Preliminary Injunction before the RTC of Manila.
Executive Judge Dela Cruz issued a TRO for a period of 72 hours enjoining petitioners or any person
acting for and in their behalf from implementing CPO 189-2013. Thereafter, the case was raffled to the
sala of Judge Laron-Cacanindin.

Petitioners alleged that the case involves personnel action affecting public officers which is under the
exclusive jurisdiction of the Civil Service Commission (CSC). Petitioners also alleged that respondents
failed to exhaust all administrative remedies available to them before filing the petition before the RTC.
Petitioners also alleged that CPO 189-2013 is an internal personnel order with application that is limited
to and only within BOC and as such, it cannot be the subject of an action for declaratory relief.

In their Comment, respondents alleged that the case involves the validity and constitutionality of CPO
189-2013, and thus, it is beyond the jurisdiction of the CSC.

In their Reply, petitioners alleged that respondents only assailed the validity of EO 140 to justify their
filing of an action for declaratory relief.

ISSUES:

Whether or not the RTC has jurisdiction over the action for declaratory relief filed by respondents

HELD:

We rule that the Regional Trial Court has jurisdiction over the action for declaratory relief filed by
respondents.

A reading of the petition filed before the RTC shows that respondents were questioning their mass detail
and reassignment to CPRO. According to respondents, their detail was carried out in bad faith and was
meant to remove them from their permanent positions in the BOC. The action appears to be a personnel
action under the jurisdiction of the CSC.

When respondents raised the issue of validity and constitutionality of CPO 189-2013, the issue took the
case beyond the scope of the CSC's jurisdiction because the matter is no longer limited to personnel
action. Thus, the RTC did not abuse its discretion in taking cognizance of the action.

Petitioners allege that respondents failed to exhaust their administrative remedies before filing the case
with the RTC.

The doctrine of exhaustion of administrative remedies allows administrative agencies to carry out their
functions and discharge their responsibilities within the specialized areas of their respective
competence.8 The doctrine entails lesser expenses and provides for the speedier resolution of
controversies.9 Therefore, direct recourse to the trial court, when administrative remedies are available,
is a ground for dismissal of the action.

The doctrine, however, is not without exceptions. Among the exceptions are: (1) where there is estoppel
on the part of the party invoking the doctrine; (2) where the challenged administrative act is patently
illegal, amounting to lack of jurisdiction; (3) where there is unreasonable delay or official inaction that
will irretrievably prejudice the complainant; (4) where the amount involved is relatively so small as to
make the rule impractical and oppressive; (5) where the question involved is purely legal and will
ultimately have to be decided by the courts of justice; (6) where judicial intervention is urgent; (7) where
the application of the doctrine may cause great and irreparable damage; (8) where the controverted acts
violate due process; (9) where the issue of non-exhaustion of administrative remedies had been
rendered moot; (10) where there is no other plain, speedy and adequate remedy; (11) where strong
public interest is involved; and (12) in quo warranto proceedings. 10cralawrednad

In this case, respondents allege that CPO 189-2013 is contrary to law and unconstitutional. Respondents
assail CPO 189-2013 as patently illegal, arbitrary, and oppressive. This case clearly falls within the
exceptions where exhaustion of administrative remedies need not be resorted to by respondents.