Case Digest (G.R. No. 184389)
Facts:
In Joaquin Berbano, Trinidad Berbano, and Melchor Berbano v. Heirs of Roman Tapulao, the petitioners challenged the Regional Trial Court (RTC) of Tuguegarao City’s jurisdiction in Civil Case No. 7899, where respondents Albert D. Tapulao, Danilo D. Tapulao, Marieta Tapulao-Reyes, Linda Tapulao-Ramirez, and Josefina Tapulao-Dacanay (represented by attorney-in-fact Josefina Tapulao-Dacanay) sought recovery of possession and damages over Lot No. 1072, Pls-492-D, Taguing, Baggao, Cagayan under Original Certificate of Title No. P-9331. The complaint alleged that Roman Tapulao, deceased registered owner, left the 18,512 sqm parcel with an assessed value of ₱22,070.00, which respondents continued to pay taxes on after his death. A relocation survey disclosed that petitioners occupied portions of the lot; demands to vacate were ignored. Petitioners countered that the lot’s true owner was Felipe Peña, who in 1954 had ceded half a hectare to Joaquin Berbano, and that a 1976 affidavit by Ro...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)