Title
Agarrado vs. Librando-Agarrado
Case
G.R. No. 212413
Decision Date
Jun 6, 2018
A dispute over property partition arose among heirs of Rodrigo Agarrado, involving legitimate and illegitimate children. The Supreme Court dismissed the case due to jurisdictional defects, as the complaint failed to allege the property's assessed value, rendering proceedings null and void.
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Case Digest (G.R. No. 212413)

Facts:

Family Background and Property Ownership

  • The petitioners, Ma. Rosario Agarrado, Ruth Librada Agarrado, and Roy Agarrado, are the legitimate children of the late spouses Rodrigo and Emilia Agarrado.
  • The spouses acquired a 287-square meter land in Bacolod City, Negros Occidental, registered under Transfer Certificate of Title No. T-29842-B.
  • Emilia died intestate on August 18, 1978, leaving Rodrigo and their children as her compulsory heirs.

Rodrigo’s Second Family

  • Unknown to the petitioners, Rodrigo had an illicit affair with respondent Cristita Librando-Agarrado, resulting in the birth of respondent Ana Lou Agarrado-King on September 27, 1978, one month after Emilia’s death.
  • Rodrigo married Cristita on July 6, 1981.
  • Rodrigo died on December 8, 2000, leaving behind Cristita, his legitimate children from his first marriage, and Ana Lou.

Partition Complaint

  • On January 23, 2003, Cristita and Ana Lou filed a complaint for partition of the subject property before the Regional Trial Court (RTC), Branch 44, Bacolod City, naming Ma. Rosario, Ruth, Roy, and "other heirs of Rodrigo Agarrado" as defendants.
  • The RTC ruled in favor of partition, ordering the parties to divide the property among themselves. The Court of Appeals (CA) affirmed the RTC’s decision but modified the shares, allocating:
    • Cristita: 2/9 of the property.
    • Ma. Rosario, Ruth, and Roy: 6/9 plus 1/4 to be divided equally.
    • Ana Lou: 1/9 of the property.

Petitioners’ Arguments

  • The petitioners challenged the CA’s decision, arguing:
    1. The CA erred in excluding five other heirs (children from the first marriage) due to the alleged failure to prove their filiation.
    2. The CA failed to appreciate implied recognition or "admission by silence" under Section 32 of Rule 130 of the Rules of Court as evidence of filiation.
    3. The CA misapplied the formula for determining shares under the Family Code and Civil Code.
    4. The CA incorrectly ruled that the family home could not be recognized as such because it was not registered.
    5. The CA failed to consider that GSIS, PHILHEALTH, and other benefits received by the respondents should be charged against their share of the estate.
    6. The CA erred in not dismissing the case for failure to allege the market value of the property and pay the correct docket fees.

Issue:

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Ruling:

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Jurisdictional Issue

  • The Court held that the complaint must be dismissed for failure to allege the assessed value of the subject property, which is essential to determine jurisdiction under Sections 19(2) and 33(3) of the Judiciary Reorganization Act of 1980, as amended.
  • The CA erred in relying on Russel vs. Vestil, as the case involved the annulment of a document, not partition. In partition cases, the assessed value of the property determines jurisdiction.
  • The Court emphasized that jurisdiction is conferred by law and cannot be waived or acquired through consent or acquiescence.
  • Since the complaint failed to indicate the assessed value of the property, the RTC lacked jurisdiction, and all proceedings were null and void.

Other Issues

  • The Court found it unnecessary to address the other issues raised by the petitioners due to the jurisdictional defect.

Ratio:

  1. Jurisdiction in Partition Cases: Actions for partition, while incapable of pecuniary estimation, are subject to jurisdictional rules based on the assessed value of the property. The court’s jurisdiction is determined by the assessed value as alleged in the complaint or evident from attached documents.
  2. Failure to Allege Assessed Value: The failure to allege the assessed value of the property in the complaint is fatal to the case, as it prevents the court from determining whether it has jurisdiction.
  3. Dismissal for Lack of Jurisdiction: A complaint that fails to comply with jurisdictional requirements must be dismissed without prejudice to refiling in the proper court.
  4. Jurisprudence on Jurisdiction: The Court reiterated the rule in Foronda-Crystal vs. Son that jurisdiction over partition cases depends on the assessed value of the property, and failure to allege this value warrants dismissal.

Conclusion:

The Supreme Court dismissed the complaint for lack of jurisdiction due to the failure to allege the assessed value of the subject property. The Court emphasized that jurisdiction is a fundamental requirement and cannot be waived or overlooked. The dismissal is without prejudice to refiling in the proper court.


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