Case Digest (G.R. No. 196874)
Facts:
Petitioners, THE HEIRS OF THE LATE SPOUSES ALEJANDRO RAMIRO AND FELICISIMA LLAMADA, appealed to the Supreme Court from the Court of Appeals' October 19, 2010 Decision and May 3, 2011 Resolution affirming the July 13, 2007 Decision of the Regional Trial Court (Branch 32, Lupon, Davao Oriental) in Civil Case No. 1966 (045). Respondent purchasers, SPOUSES ELEODORO AND VERNA BACARON, alleged a Deed of Sale dated October 20, 1991 over Lot 329, Cad-600 (OCT No. P-12524, about 48,639 sq.m.), claimed redemption from a DBP mortgage by payment of P430,150.00, and averred that petitioners forcibly dispossessed them in June 1998.
The RTC ruled for SPOUSES BACARON declaring the sale valid and ordering possession restored; the CA affirmed; petitioners questioned jurisdiction, characterization of the transaction as an equitable mortgage, and laches, prompting this Rule 45 petition.
Issues:
- Did the RTC acquire jurisdiction over the subject matter of the action?
- Should the Deed of Sale dated October 20, 1991 be treated as an equitable mortgage?
- Are SPOUSES BACARON's claims barred by laches?
Ruling:
The Court GRANTED the petition. It held that the action primarily involved title to or possession of real property and that the RTC lacked jurisdiction because the amended complaint did not allege the assessed or estimated value of the property and the proper docket fees were not shown to have been paid. Consequently, the CA Decision and Resolution and the RTC Decision were REVERSED and SET ASIDE, and the amended complaint was dismissed without prejudice. The Court found no need to resolve the equitable mortgage and laches issues.
Ratio:
The Court applied the rule that the nature of the action is determined by the material allegations and the reliefs sought; although styled as specific performance or declaration, the complaint's averments and prayers showed a primary objective to recover title or possession. Under B.P. Blg. 129, as amended by R.A. No. 7691, jurisdiction for real actions depends on the assessed value of the property, which must be alleged by the claimant because the Court cannot take judicial notice of assessed or market value; payment of the correct docket fee is required to vest subject-matter jurisdiction. Absent the assessed or estimated value and proper docket fees, the proceedings were void.
Doctrine:
- The nature of an action is determined by the complaint's material allegations and the reliefs prayed for, not merely by its caption or label.
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