Title
Berbano vs. Heirs of Tapulao
Case
G.R. No. 227482
Decision Date
Jul 1, 2019
Heirs of Tapulao sued Berbanos for land recovery; jurisdictional dispute arose over assessed value. SC upheld RTC jurisdiction, affirming Tapulao's ownership.

Case Digest (G.R. No. 184389)

Facts:

  • Parties and Property
    • Petitioners are Joaquin Berbano, Trinidad Berbano, and Melchor Berbano, who occupied portions of a parcel of land in Taguing, Baggao, Cagayan.
    • Respondents are the heirs of Roman Tapulao—Albert D. Tapulao, Danilo D. Tapulao, Marieta Tapulao-Reyes, Linda Tapulao-Ramirez, and Josefina Tapulao-Dacanay—registered owners of the same lot covered by Original Certificate of Title No. P-9331.
  • Trial Court Proceedings
    • Respondents filed a Complaint for Recovery of Possession and Damages, alleging ownership of an 18,512-sqm lot with an assessed value of ₱22,070.00. They requested petitioners to vacate the portion they occupied.
    • Petitioners answered, claiming they had acquired half a hectare by cession in 1954 and that a survey error led to the land being included in Tapulao’s title. They admitted occupation but insisted on their own title and sought transfer of registration and damages.
    • During eight pre-trial resets, petitioners’ counsel repeatedly failed to appear. On January 30, 2014, the court granted respondents’ motion to present evidence ex parte.
    • By Judgment dated August 1, 2014, the RTC declared respondents rightful owners, ordered petitioners to vacate, and awarded actual damages of ₱4,131.00. Petitioners’ motion for reconsideration was denied on the ground that the complaint itself alleged an assessed value of ₱22,070.00.
  • Court of Appeals and Supreme Court Proceedings
    • On appeal, petitioners first contested jurisdiction, arguing that only a 6,804-sqm portion (assessed at ₱8,111.72) was in dispute, placing the case within MTC jurisdiction. They also claimed lack of notice at pre-trial.
    • The Court of Appeals, in its September 30, 2016 Decision, affirmed the RTC, ruling that the assessed value alleged in the complaint exceeded ₱20,000.00, conferring RTC jurisdiction.
    • Petitioners sought review before the Supreme Court, reiterating their jurisdictional argument. Respondents maintained that jurisdiction is governed by the value alleged in the complaint.

Issues:

  • Whether petitioners’ challenge to the RTC’s jurisdiction over the subject matter is tenable.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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