Case Digest (G.R. No. 179457)
Facts:
On February 14, 2000, Petitioners filed a complaint for reconveyance of ownership and possession with damages in Municipal Trial Court (MTC) Bolinao, Pangasinan, alleging long continuous possession of portions of Lot No. 7303 and that Respondents had improperly secured Free Patent titles over the same land; tax declarations attached to the complaint showed an assessed value totaling P54,370.00. The MTC dismissed the complaint and declared respondents lawful owners on November 9, 2001; the Regional Trial Court (RTC), on appeal, reversed on June 14, 2002 and ordered reconveyance and damages; the Court of Appeals (CA) annulled both lower-court decisions for lack of jurisdiction on May 29, 2007.
Issues:
- Did the Court of Appeals err in annulling the RTC Decision for lack of jurisdiction?
- May the RTC decide the merits on appeal where the MTC tried the case despite lack of jurisdiction under Section 8, Rule 40?
Ruling:
The Court granted the petition, reversed and set aside the CA Decision and its Resolution, and remanded the case to the CA for resolution of the factual issues raised in respondents' petition for review of the RTC Decision. The Court held that while the MTC lacked jurisdiction, the RTC properly exercised appellate jurisdiction and correctly decided the case on the merits on appeal.
Ratio:
Jurisdiction over the subject matter is determined by the allegations in the complaint; the attached tax declarations showed an assessed value in excess of P20,000.00, thereby vesting original jurisdiction in the RTC under Section 19(2), B.P. Blg. 129, as amended. Moreover, Section 8, Rule 40 authorizes the RTC on appeal to decide a case on the merits when the lower court tried it despite lack of jurisdiction, and Section 22, B.P. Blg. 129 vests the RTC with appellate jurisdiction over MTC decisions irrespective of amount. Because the petition under Rule 45 raises only questions of law, the Court remanded the unresolved factual issues to the CA for determination.
Doctrine:
- Jurisdiction is conferred by law and is determined by the allegations in the complaint.
- The RTC has exclusive original jurisdiction over civil actions involving title or possession of real property with assessed value exceeding P20,000 per Section 19(2), B.P. Blg. 129.
- Where a lower court without jurisdiction tried a case on the merits, the RTC on appeal may decide the case on the merits under Section 8, Rule 40.
- The RTC exercises appellate jurisdiction over cases decided by MTCs pursuant to Section 22, B.P. Blg. 129.
- A petition under Rule 45 is limited to questions of law, and factual disputes should be remanded for proper resolution.