Case Digest (G.R. No. L-12219)
Facts:
In G.R. No. 221815 decided on November 29, 2017 under the 1987 Constitution, petitioner Glynna Foronda-Crystal is the daughter of Eddie Foronda, registered owner of Lot 1280 in Barrio Magay, Compostela, Cebu, by virtue of Free Patent No. VII-519533 covered by Original Certificate of Title (OCT) No. OP-37324. On March 15, 1999, respondent Aniana Lawas Son filed before the Regional Trial Court (RTC), Branch 55 in Mandaue City, an action for reconveyance and damages, alleging that she had bought Lot 1280 from Eleno T. Arias on August 4, 1986 for ₱200,000.00, continuously possessed it, and paid real property taxes evidenced by Tax Declaration No. 16408A. She maintained that the Free Patent in favor of Eddie Foronda was issued through “gross error,” since no tax declarations were ever in his name. Petitioner moved to dismiss for lack of jurisdiction, improper venue, prescription, and lack of cause of action. Initially, on April 20, 1999, the RTC dismissed the case for lack of jurisdiCase Digest (G.R. No. L-12219)
Facts:
- Parties
- Petitioner: Glynna Foronda-Crystal, daughter of Eddie Foronda, registered owner of Lot 1280, Barrio Magay, Compostela, Cebu, by virtue of Free Patent No. VII-519533 covered by OCT No. OP-37324.
- Respondent: Aniana Lawas Son, alleged purchaser of the same lot from Eleno T. Arias on August 4, 1986 for ₱200,000.00, holding Tax Declaration No. 16408A in her name.
- Antecedent Proceedings
- March 15, 1999: Respondent filed an action for reconveyance and damages before RTC Branch 55, Mandaue City, alleging 12½-year possession, payment of real property taxes, and that the Free Patent to Eddie Foronda was issued by gross error.
- April 20, 1999: RTC dismissed the case for lack of jurisdiction, citing a P2,830.00 market value per Tax Declaration No. 16408.
- July 23, 1999: RTC set aside its dismissal, held that complaint alleged P200,000.00 value and that BIR zonal valuation justified RTC jurisdiction, and thus ordered trial on the merits.
- November 24, 2006: RTC rendered judgment declaring OCT No. OP-37324 null and void for grave error, ordering cancellation and issuance of new title in respondent’s name; no pronouncement on damages or costs.
- March 12, 2015: Court of Appeals (CA) in CA-G.R. CV No. 02226 affirmed the RTC Decision in toto.
- October 19, 2015: CA denied petitioner’s motion for reconsideration.
- Petitioner filed a Rule 45 petition for review on certiorari before the Supreme Court.
Issues:
- Jurisdiction
- Whether the RTC of Mandaue City validly acquired subject-matter jurisdiction over the reconveyance action involving Lot 1280, given the assessed value under Tax Declaration No. 16408A.
- Whether the RTC decision is void ab initio for lack of jurisdiction.
- Cancellation of Title
- Whether OCT No. OP-37324 issued to Eddie Foronda must be canceled and a new title issued to respondent based on her allegations of ownership and possession.
- Prescription
- Whether the action for reconveyance and damages is already barred by prescription or laches.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)