In Mandaue Realty & Resources Corporation v. Bangko Sentral ng Pilipinas, the Supreme Court clarified the proper procedure for appealing decisions from Regional Trial Courts (RTCs) involving mixed questions of law and fact. The Court ruled that when an appeal involves both factual and legal issues, it should be brought before the Court of Appeals (CA) through an ordinary appeal under Rule 41 of the Rules of Court, and not directly to the Supreme Court. This decision ensures that factual disputes are first resolved at the appellate level, streamlining the judicial process and promoting judicial efficiency. This ruling underscores the importance of correctly identifying the nature of the issues raised in an appeal to ensure it is filed with the appropriate court, avoiding delays and potential dismissal.

Title Tussles: Did the Court of Appeals Overstep in Hearing BSP’s Land Dispute Appeal?

The case revolves around a land dispute between Mandaue Realty & Resources Corporation (MARRECO) and Bangko Sentral ng Pilipinas (BSP). BSP filed a complaint seeking to annul MARRECO’s title to a property, arguing that a previous court order nullifying BSP’s title was invalid. MARRECO countered by filing a Motion to Dismiss, asserting that the Regional Trial Court (RTC) lacked jurisdiction because the complaint sought to overturn a final judgment by a co-equal court. MARRECO also argued that the principle of res judicata barred BSP’s claim, and that BSP was guilty of forum shopping. The RTC granted MARRECO’s motion, dismissing BSP’s complaint for lack of jurisdiction. BSP then appealed to the Court of Appeals (CA), prompting MARRECO to file a Motion to Dismiss the Appeal, contending that BSP’s appeal raised only questions of law, which should have been brought directly to the Supreme Court.

The central issue before the Supreme Court was whether the CA committed grave abuse of discretion when it denied MARRECO’s Motion to Dismiss Appeal and assumed jurisdiction over BSP’s appeal. This hinges on whether the issues raised in BSP’s appeal were purely questions of law or involved mixed questions of law and fact. To resolve this, the Supreme Court examined the distinction between questions of law and questions of fact. A question of law arises when there is doubt or controversy about what the law is on a certain set of facts. Conversely, a question of fact exists when the doubt or difference arises as to the truth or falsehood of the facts.

The Supreme Court emphasized the importance of correctly identifying the nature of the issues raised in an appeal, as it determines the proper venue for the appeal. Section 2, Rule 41 of the Rules of Court outlines the modes of appeal from judgments and final orders of the RTC. Specifically, it states that if the issues raised involve questions of fact or mixed questions of fact and law, the proper recourse is an ordinary appeal to the CA. However, if the issues raised involve only questions of law, the appeal shall be to the Court by petition for review on certiorari. This distinction is crucial because it dictates whether an appeal should be filed with the CA or directly with the Supreme Court.

In determining whether the CA acted correctly in assuming jurisdiction over BSP’s appeal, the Supreme Court analyzed the issues raised in BSP’s Appellant’s Brief. These issues included whether the trial court erred in concluding that it lacked jurisdiction, whether the trial court erroneously interpreted the previous court order, and whether the order dismissing the case disregarded the provisions of the Civil Code on quieting of title. BSP argued that the trial court’s order did not direct the cancellation of TCT No. 46781, and that the Register of Deeds’ subsequent cancellation of the title compelled BSP to file an action for annulment of title and reconveyance. BSP also contended that it was a mortgagee-in-good-faith and not bound by any transactions between Gotesco and MARRECO.

After careful consideration, the Supreme Court concluded that BSP’s appeal involved not only questions of law but also questions of fact. The Court noted that the allegations in BSP’s complaint and appellant’s brief regarding the circumstances leading to the cancellation of TCT No. 46781 created uncertainty as to the propriety of the trial court’s pronouncement. The Court held that these matters called for a calibration of the evidence on record, making it a question of fact rather than a question of law. The appellate court emphasized this point:

It is indubitable that what impelled BSP to file the instant complaint for annulment of title and reconveyance or quieting of title before RTC Branch 56, docketed as Civil Case No. Man-5524 is not the Decision of January 19, 2004 rendered by RTC, Branch 55 in Civil Case No. Man-3902 but the subsequent cancellation of BSP’s title without any court order to that effect. From this premise, the issue on whether or not the assumption of jurisdiction over the instant case is equivalent to annulment of judgment of a co­equal tribunal is considered a question of fact.

Given the presence of mixed questions of law and fact, the Supreme Court ruled that BSP properly elevated the RTC’s March 22, 2007 Order to the CA on ordinary appeal under Rule 41, Section 2 of the Rules of Court. The Court emphasized that:

If the issues raised involve questions of fact or mixed questions of fact and law, the proper recourse is an ordinary appeal to the CA in accordance with Rule 41 in relation to Rule 44 of the Rules of Court.

The Supreme Court dismissed MARRECO’s Petition for Certiorari and Mandamus and affirmed the Resolutions of the Court of Appeals. This decision reinforces the procedural rules governing appeals in the Philippines and clarifies the distinction between questions of law and questions of fact. Understanding this distinction is essential for litigants and legal practitioners to ensure that appeals are filed with the correct court, thereby avoiding delays and ensuring the efficient administration of justice.

This case highlights the need for a careful assessment of the issues presented in an appeal. Litigants must analyze whether the appeal involves questions of fact, questions of law, or mixed questions of law and fact. The Supreme Court’s decision in Mandaue Realty provides guidance on how to make this determination and emphasizes the importance of adhering to the procedural rules outlined in the Rules of Court. Moreover, the principle that questions of fact must be established at the appellate level before being elevated to the Supreme Court ensures efficiency in the judicial process.

Ultimately, the Supreme Court’s ruling in Mandaue Realty serves as a reminder to litigants and legal practitioners of the importance of understanding and adhering to the procedural rules governing appeals in the Philippines. By correctly identifying the nature of the issues raised in an appeal and following the appropriate procedures, parties can ensure that their cases are heard by the proper court and that justice is administered efficiently and effectively.

FAQs

What was the key issue in this case?	The key issue was whether the Court of Appeals (CA) acted with grave abuse of discretion in assuming jurisdiction over an appeal that Mandaue Realty & Resources Corporation (MARRECO) claimed involved only questions of law.
What is the difference between a question of law and a question of fact?	A question of law involves uncertainty about the applicable law to a given set of facts, while a question of fact involves uncertainty about the truth or falsehood of the facts themselves.
Which court should hear an appeal involving mixed questions of law and fact?	An appeal involving mixed questions of law and fact should be brought before the Court of Appeals (CA) through an ordinary appeal under Rule 41 of the Rules of Court.
What is the significance of Rule 41 of the Rules of Court?	Rule 41 of the Rules of Court governs appeals from judgments and final orders of the Regional Trial Court (RTC), specifying the procedures for ordinary appeals based on the nature of the issues raised.
What was Bangko Sentral ng Pilipinas (BSP) seeking in its complaint?	BSP sought the annulment of MARRECO’s title to a property and the reinstatement of BSP’s title, arguing that a previous court order nullifying BSP’s title was invalid.
Why did MARRECO file a Motion to Dismiss BSP’s appeal?	MARRECO filed a Motion to Dismiss the Appeal, contending that BSP’s appeal raised only questions of law, which should have been brought directly to the Supreme Court, not the Court of Appeals.
What did the Supreme Court ultimately decide in this case?	The Supreme Court dismissed MARRECO’s petition and affirmed the Resolutions of the Court of Appeals, holding that BSP’s appeal involved mixed questions of law and fact, properly brought before the CA.
What is the practical implication of this decision for litigants?	The decision underscores the importance of correctly identifying the nature of the issues raised in an appeal to ensure it is filed with the appropriate court, avoiding delays and potential dismissal.

In conclusion, the Mandaue Realty case serves as a crucial reminder of the procedural distinctions between appeals involving questions of law and those involving mixed questions of law and fact. Understanding these distinctions and adhering to the prescribed rules is essential for ensuring that appeals are properly filed and that justice is administered efficiently.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: Mandaue Realty & Resources Corporation v. Bangko Sentral ng Pilipinas, G.R. No. 185082, November 28, 2016