G.R. No. L-23815 - Ledesma vs. Climaco

On August 28, 1998, petitioners filed a complaint for reconveyance and damages before the Regional Trial Court (RTC), Branch 18, Digos, Davao del Sur.
The complaint sought the issuance of a temporary restraining order and/or a writ of preliminary injunction against respondent Ignacio Talip, representing the heirs of Juan Jayag.

The disputed property consists of a parcel of land of 3.2 hectares situated in Piapi, Padada, Davao del Sur.
It is covered by Original Certificate of Title (OCT) No. P-(3331)-4244 issued in the name of Juan Jayag.
The land’s market value was stated as ₱15,000.00, and the parcel was later subdivided into lots of 100 square meters each, on which the individual petitioners built their houses.
Additional structures on the remaining portion include the barangay center, a multi-purpose gym, and a health center.

Petitioners and their predecessors-in-interest have possessed the parcel for more than 30 years in an actual, peaceful, continuous, and public manner.
They alleged that respondent fraudulently obtained a Transfer Certificate of Title (TCT) from the Registry of Deeds in his name.
It was noted that respondent paid real estate taxes in 1998 and threatened to erect a barb-wire fence around the property.
The petitioners' complaint did not allege the assessed value of the property, but merely stated its market value.

Respondent moved to dismiss the complaint by asserting that the RTC lacked jurisdiction because the assessed value of the property was only ₱6,030.00.
He cited Section 33(3) of Batas Pambansa Blg. 129 (as amended by R.A. No. 7691), contending that the case, based on the property’s valuation, should be heard by the Municipal Circuit Trial Court of Padada-Kiblawan, Davao del Sur.
In opposition, petitioners submitted a Real Property Field Appraisal and Assessment Sheet (dated August 20, 1996) indicating an assessed value of ₱41,890.00, arguing thereby that the RTC had jurisdiction.

On January 12, 1999, the RTC dismissed the complaint for lack of jurisdiction based on the allegation that the assessed value of the property did not meet the threshold necessary for RTC jurisdiction.
A subsequent motion for reconsideration by petitioners was denied on April 20, 1999.
Petitioners then elevated the issue to the Supreme Court through a petition for review on certiorari.

Whether the Regional Trial Court had jurisdiction over the complaint for reconveyance given that the petitioners' pleading only stated the market value (₱15,000.00) of the property, rather than its assessed value.
Whether the nature of the action—specifically involving title to or possession of real property—requires an allegation of the assessed value to determine the proper venue as mandated by Section 7(b), Rule 141 of the Revised Rules of Court and Batas Pambansa Blg. 129.
Whether the petitioners’ claim, by failing to allege the property’s assessed value, falls within the exclusive jurisdiction of the Municipal Circuit Trial Court instead of the RTC.