Case Digest (G.R. No. 174908) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Darma Maslag v. Elizabeth Monzon, William Geston, and the Registry of Deeds of La Trinidad, Benguet (G.R. No. 174908, June 17, 2013), petitioner Darma Maslag filed on March 17, 1998 before the Municipal Trial Court (MTC) of La Trinidad, Benguet, a Complaint for reconveyance of real property with declaration of nullity of Original Certificate of Title (OCT) against respondents Monzon, Geston, and the Registry of Deeds. Petitioner alleged that she contributed to a common fund for survey in 1987 but that respondents fraudulently omitted her name when OCT P-3034 was issued for 18,295 square meters of land, of which she occupied 4,415 square meters. On June 11, 2001, the MTC found Monzon guilty of fraud, ordered reconveyance of the 4,415 square meters, and awarded exemplary damages, attorney’s fees, and costs. Respondents appealed to the Regional Trial Court (RTC), which on October 22, 2003 issued an Order declaring the MTC without jurisdiction under Section 8, Rule 40 of the Rule Case Digest (G.R. No. 174908) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Factual Background
- In 1998, petitioner Darma Maslag filed before the Municipal Trial Court (MTC) of La Trinidad, Benguet a complaint for reconveyance of real property with declaration of nullity of Original Certificate of Title (OCT) against respondents Elizabeth Monzon, William Geston, and the Registry of Deeds of Benguet.
- Petitioner alleged open, continuous, notorious, and exclusive possession of the disputed property since the 1940s and claimed that Monzon fraudulently omitted her name from the title despite contributing to the subdivision survey fund.
- MTC and RTC Proceedings
- On June 11, 2001, the MTC found Monzon guilty of fraud, ordered reconveyance of the 4,415-sq.m. parcel to petitioner, awarded damages and costs.
- Respondents appealed to the Regional Trial Court (RTC). On October 22, 2003, Judge Cabato declared the MTC without jurisdiction, invoked Section 8, Rule 40 of the Rules of Court, and directed parties to submit additional evidence.
- After memoranda and no further evidence, Judge Diaz De Rivera, Jr. on May 4, 2004 reversed the MTC decision, ordered petitioner to vacate the property, and remanded for inquiry into builder’s-good-faith remedies.
- Court of Appeals Proceedings
- Petitioner filed a Notice of Ordinary Appeal under Rule 41 against the RTC’s May 4, 2004 Resolution.
- Respondents moved to dismiss for improper remedy, asserting the RTC acted in appellate jurisdiction and Rule 42 review was proper.
- On May 31, 2006, the CA granted the motion and dismissed the appeal. On September 22, 2006, it denied petitioner’s motion for reconsideration.
- Petitioner elevated the matter to the Supreme Court via Petition for Review on Certiorari under Rule 45.
Issues:
- Mode of Appeal
- Whether the CA erred in dismissing petitioner’s ordinary appeal under Rule 41, given the RTC allegedly exercised original jurisdiction under Section 8, Rule 40.
- Jurisdictional Effect
- What is the effect of an RTC order invoking Section 8, Rule 40 when the MTC had exclusive original jurisdiction over the property dispute?
- Whether the proper remedy was a petition for review under Rule 42 or an ordinary appeal under Rule 41.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)