TL;DR

The Supreme Court clarified that dismissing a case based on the wrong Regional Trial Court branch within the same jurisdiction is an error of venue, not jurisdiction. This means the case was filed in the right type of court (RTC), but potentially the wrong branch. The Court emphasized that venue objections must be raised early and are waivable. In this case, since the respondents did not object to the venue in the lower court, the Regional Trial Court’s decision on the validity of a land sale agreement was valid. The Supreme Court reversed the Court of Appeals’ decision, reinstating the RTC’s ruling that upheld the Deed of Sale with Assumption of Mortgage, finding it a valid contract based on the clear terms of the written agreement and the parol evidence rule.

Navigating Court Errors: When a Wrong Branch Doesn’t Void a Right

When Federico Alferez passed away intestate, the settlement of his estate began in the Court of First Instance (CFI), Branch 5. Years later, a case concerning a land sale from his estate was filed in Regional Trial Court (RTC), Branch 19. The Court of Appeals (CA) declared the RTC Branch 19’s judgment void, claiming it lacked jurisdiction because the estate settlement was already with CFI Branch 5. The central legal question is: Did filing the case in a different branch of the RTC, when probate proceedings were in another branch of the same court, truly strip the RTC of its jurisdiction, or was it merely an issue of proper venue? This case delves into the crucial distinction between jurisdiction and venue, and the consequences of procedural missteps in legal proceedings, especially concerning estate matters and contractual obligations.

The Supreme Court firmly stated that the CA erred in equating venue with jurisdiction. Jurisdiction, the power of a court to hear and decide a case, is conferred by law. For probate matters, the Regional Trial Court (formerly CFI) has original jurisdiction. Venue, on the other hand, is about the place where the case should be heard, governed by rules of procedure. The Court cited Republic Act No. 296 and Republic Act No. 7691 to underscore that RTCs have jurisdiction over probate matters, regardless of which branch within the judicial region handles the case. The appellate court’s reliance on Rule 73, Section 1 of the Rules of Court was misplaced, as this rule pertains to venue—specifying where within the RTC jurisdiction the case should ideally be filed—not jurisdiction itself.

Section 1. Where estate of the deceased persons settled.— If the decedents is an inhabitant of the Philippines at the time of his death, whether a citizen or an alien, his will shall be proved, or letters of administration granted, and his estate settled, in the Court of First Instance in the province in which he resides at the time of his death, and if he is an inhabitant of a foreign country, the Court of First Instance of any province in which he had estate. The court first taking cognizance of the settlement of the estate of a decedent, shall exercise jurisdiction to the exclusion of all other courts.

The Supreme Court emphasized that objections to venue are waivable if not raised promptly. In this case, the respondents actively participated in the RTC Branch 19 proceedings without objecting to the venue, thus waiving any such objection. The Court highlighted the crucial difference between jurisdictional errors, which are fundamental and cannot be waived, and venue errors, which are procedural and can be waived by the parties’ actions or inaction. Furthermore, the Court noted that a probate court’s jurisdiction is limited to estate matters and generally does not extend to resolving ownership disputes with third parties. Since the case involved a contract of sale with non-heirs (the respondents), the RTC Branch 19, acting as a court of general jurisdiction, was the proper forum to determine the validity of the Deed of Sale with Assumption of Mortgage.

Turning to the validity of the Deed, the petitioners argued that it should only cover half of the property, representing Federico’s estate, not the entire conjugal property. However, the Supreme Court upheld the RTC’s finding that the Deed was valid in its entirety. The Court applied the parol evidence rule, stating that when a contract is in writing and its terms are clear, the written terms prevail. The Deed of Sale unambiguously conveyed the entire parcels of land without any reservation or mention of limiting the sale to only Federico’s share. Article 1370 of the Civil Code dictates that when contract terms are clear, their literal meaning controls.

Article 1370. If the terms of a contract are clear and leave no doubt upon the intention of the contracting parties, the literal meaning of its stipulations shall control.

The petitioners’ claim of a contrary intention, not reflected in the Deed, was deemed inadmissible under the parol evidence rule, as they failed to present compelling evidence to prove mistake, ambiguity, or failure to express true intent. The Court also pointed out that prior to the Deed, an Extrajudicial Settlement with Donation had already transferred ownership of the properties to the petitioners. Therefore, they were selling the land as owners, not merely as representatives of Federico’s estate. The Special Powers of Attorney (SPAs) further solidified Ma. Concepcion’s authority to sell on behalf of her siblings. Ultimately, the Supreme Court reinforced the principle that contracts are the law between parties and must be enforced when their terms are clear and not contrary to law or public policy.

FAQs

For inquiries regarding the application of this ruling to specific circumstances, please contact Atty. Gabriel Ablola through gaboogle.com or via email at connect@gaboogle.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: Alferez v. Canencia, G.R. No. 244542, June 28, 2021