Title
Capiral vs. Spouses Valenzuela
Case
G.R. No. 152886
Decision Date
Nov 15, 2002
Petitioner claimed tenancy rights and sought to compel sale of disputed lots; RTC dismissed for lack of jurisdiction, affirmed by SC due to monetary threshold and absence of valid agreement.
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Case Digest (G.R. No. 152886)

Facts:

  1. Background of the Case:

    • Petitioner Rosendo E. Capiral claimed to be a "tenant-tiller" since 1957 of two parcels of land in Barrio Ibayo, ParaƱaque, owned by Facundo and Lorenza Santos.
    • In 1960, the Santoses subdivided the land and sold the resulting lots, including Lots 32 and 33, to respondents Maxima Jimenez Valenzuela and Daniel Valenzuela, who obtained TCT Nos. 84665 and 84666 for the lots.
  2. Petitioner's Allegations:

    • Petitioner alleged that he entered into an agreement with Joaquin "Jack" Rodriguez, wherein Rodriguez would negotiate the purchase of the lots and give petitioner a third of the properties, preferably Lots 32 and 33.
    • Rodriguez issued a check for P347,200.00 to respondent Maxima Jimenez Valenzuela, and petitioner signed a Deed of Absolute Sale for the lots.
    • Respondents allegedly threatened to oust petitioner and his family from the lots and offered them for sale to others.
  3. Relief Sought:

    • Petitioner sought a temporary restraining order or preliminary injunction to prevent respondents from ousting him and demolishing his house.
    • He also prayed for specific performance, asking the court to compel respondents to sell the lots to him at the agreed price or pay him the market value of the improvements he made on the lots.
  4. Trial Court's Decision:

    • The Regional Trial Court (RTC) dismissed the complaint for lack of jurisdiction, as the assessed value of the lots (P336,800.00) and the damages claimed (P102,000.00) did not exceed P400,000.00, placing the case within the jurisdiction of the Municipal Trial Court (MTC).

Issue:

  1. Whether the Regional Trial Court (RTC) had jurisdiction over the case.
  2. Whether the complaint was properly dismissed for lack of jurisdiction.
  3. Whether the case falls under the jurisdiction of the Department of Agrarian Reform Adjudication Board (DARAB) as a tenancy dispute.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)


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