Title
Malana vs. Tappa
Case
G.R. No. 181303
Decision Date
Sep 17, 2009
Heirs of Anastacio Danao sought to reclaim land occupied by respondents, but RTC dismissed the case for lack of jurisdiction due to the property's low assessed value (P410.00). SC upheld dismissal, ruling quieting of title is a real action subject to jurisdictional limits, remanding to proper court.
A

Case Digest (G.R. No. 181303)

Facts:

  • Background and Ownership
    • Petitioners are six Danao heirs who claim ownership of a parcel of land in Tuguegarao City covered by TCT No. T-127937, inherited from Anastacio Danao, who died intestate.
    • During Anastacio’s lifetime, he allowed Consuelo Pauig (married to Joaquin Boncad) to occupy the southern portion of the land on condition that she vacate when the owner or heirs needed it.
  • Occupation and Dispute
    • After Consuelo’s death, respondents (her son-in-law Benigno Tappa; grandson Jerry Reyna; son-in-law Saturnino Cambri; and spouses Francisco and Maria Ligutan) continued to occupy the land, built permanent residences, and asserted ownership.
    • Petitioners demanded respondents vacate; respondents refused and, during barangay conciliation, presented allegedly falsified documents creating a cloud on petitioners’ title.
  • RTC Proceedings
    • On March 27, 2007, petitioners filed in RTC Civil Case No. 6868 a Complaint for Reivindicacion, Quieting of Title, and Damages (P50,000 actual, P50,000 exemplary, P50,000 attorney’s fees).
    • The RTC dismissed the Complaint motu proprio on May 4, 2007 for lack of jurisdiction (assessed value P410

Issues:

  • Whether the RTC committed grave abuse of discretion in dismissing petitioners’ Complaint motu proprio for lack of jurisdiction.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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