Case Digest (G.R. No. 199290)
Facts:
Municipality of Cainta, Rizal v. Spouses Ernesto E. Brana and Edna C. Brana and City of Pasig, G.R. No. 199290, February 03, 2020, Supreme Court Third Division, Carandang, J., writing for the Court.Petitioner Municipality of Cainta sought review of the Regional Trial Court of Pasig City, Branch 157 (RTC of Pasig) Decision dated June 23, 2008 in SCA No. 1624. Respondents are Spouses Ernesto E. Brana and Edna C. Brana (Sps. Brana) and the City of Pasig. The RTC of Pasig ordered Sps. Brana to pay real property taxes on six titled lots to the City of Pasig from 1996 to the present.
Sps. Brana are registered owners of six parcels in Phase 9, Pasig Green Park, Cainta covered by TCT Nos. 47350, 47351, 47352, 47353, 46600 and 46601 (the subject properties). They paid real estate taxes to Cainta from 1994 to 1996. In 1997 the City of Pasig assessed the properties and filed Civil Case No. 5525 for collection of unpaid taxes against Sps. Brana; Sps. Brana deposited tax checks with the MTC of Pasig where that case was pending. Because Cainta continued to demand taxes, Sps. Brana filed an interpleader action in the RTC of Pasig on June 26, 1998 to have Cainta and Pasig litigate their competing claims.
Unrelatedly, on January 30, 1994 the Municipality of Cainta had earlier filed a boundary dispute against the City of Pasig in the RTC of Antipolo, Branch 74, docketed Civil Case No. 94-3006, which included the subject properties among the territories in dispute. On December 16, 2002 the Antipolo RTC issued an Injunction Order enjoining Pasig from further collecting taxes, pursuing auctions, asserting jurisdictional title, and ordering reimbursement of taxes collected from affected residents.
In the RTC of Pasig interpleader case, the City of Pasig argued that the TCT locational entries place the properties in Brgy. Santolan, Municipality of Pasig, and that Department of Finance (DOF) practice and the Implementing Rules of the Local Government Code make the title location controlling unless corrected by competent authority. The Municipality of Cainta asserted longstanding assessment and collection by Cainta and relied on the cadastral CAD-688-D entries. On June 23, 2008, the RTC of Pasig ruled for the City of Pasig and ordered Sps. Brana to pay unpaid realty taxes from 1996 to the present to Pasig.
Aggrieved, the Municipality of Cainta filed a Petition for Review on Certiorari directly with the Supreme Court, contending that the RTC of Pasig exceeded its jurisdiction and interfered with the Antipolo RTC’s ...(Pro-only)
Issues:
- May the Municipality of Cainta directly appeal to the Supreme Court by petition for review on certiorari under Rule 41(2)(c) when only questions of law are involved?
- Did the RTC of Pasig err in ordering Sps. Brana to pay real estate taxes to the City of Pasig despite the pending boundary dispute and the A...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)