Title
Padre vs. Badillo
Case
G.R. No. 165423
Decision Date
Jan 19, 2011
A property dispute arose when defendants re-entered land post-1986 judgment; MTC ruled for plaintiffs, but SC overturned, citing lack of jurisdiction as it was an accion publiciana exceeding MTC's limit.

Case Digest (G.R. No. 165423)
Expanded Legal Reasoning Model

Facts:

  • Background of the Original Judgment
    • In Civil Case No. A-514 decided on October 13, 1986 by the RTC of Allen, Northern Samar, Branch 23:
      • The case involved an action for ownership and recovery of possession with damages.
      • The judgment declared the Badillo family (plaintiffs) to be the lawful owners of the five-sixth (5/6) portion of Lot No. 4080, Pls-54, as evidenced by the Original Certificate of Title No. 736 and a delineated Sketch Plan (Exhibit “B-1”).
      • The decision ordered the defendants, including Consesa Padre among others, to vacate the properties and restore the belongings of the plaintiffs.
      • The judgment also imposed monthly rental payments, attorney’s fees, litigation expenses, and costs.
    • Finality of the Judgment
      • The decision became final and executory on November 5, 1986.
  • Filing of the Revival of Judgment
    • On December 29, 1997, the Badillo family filed a new complaint (Civil Case No. 104) with the Municipal Trial Court (MTC) of San Isidro, Northern Samar.
      • The suit aimed to enforce the previously rendered judgment by compelling the defendants (occupants) to vacate the property.
      • Although framed as an action for “Ownership and Possession,” the complaint incorporated allegations showing that the plaintiffs were the prevailing parties in the earlier RTC case.
    • Involvement of Nilo Padre
      • Nilo Padre, heir of the deceased Consesa Padre, was impleaded as one of the defendants.
      • While some defendants answered the complaint, Nilo was declared in default for failing to file an answer.
  • Proceedings in the Municipal Trial Court (MTC)
    • MTC’s Judgment Rendered on July 17, 2003
      • The MTC interpreted the case as a revival of the dormant judgment (rather than a new real action for ownership).
      • It affirmed the right of the Badillo family to enforce the RTC judgment by ordering:
        • Affirmation of the plaintiffs’ title over the specified five-sixth portion of the property.
        • Ordering defendants to vacate the lots occupied by them.
        • Imposition of joint and several liabilities for attorney’s fees, litigation expenses, and exemplary damages.
    • Nilo Padre’s Motion for Reconsideration before the MTC
      • He contested the MTC’s jurisdiction on several grounds:
        • Arguing that the action for revival of judgment is essentially a real action and should have been filed before the RTC.
        • Highlighting that the assessed value of the property (P26,940.00) exceeds the MTC’s jurisdictional threshold under RA No. 7691.
        • Claiming issues of prescription and the absence of a certificate of non-forum shopping.
      • The MTC denied the motion for reconsideration, upholding its decision and characterizing the suit as a personal action.
  • Proceedings in the Regional Trial Court (RTC)
    • Petition for Certiorari and Jurisdictional Challenge
      • Nilo elevated the case to the RTC via Special Civil Action No. A-927, reiterating his objections regarding the MTC’s jurisdiction.
      • On July 21, 2004, the RTC dismissed the petition on timeliness but simultaneously reaffirmed the MTC’s authority by ruling that enforcing a dormant judgment constituted a personal action.
    • Motion for Reconsideration before the RTC
      • Nilo argued that his petition was timely filed since the date of mailing (March 1, 2004) should be considered the filing date.
      • He maintained that the jurisdictional issue – that an action to revive a dormant judgment involving a property assessed over P20,000.00 should be filed with the RTC – was not adequately addressed.
    • RTC’s Order of September 20, 2004
      • The RTC denied Nilo’s motion for reconsideration on timeliness grounds (noting that filing occurred 61 days after the reckoning period began).
      • The court reaffirmed that the action was personal in nature and within the rules, and held that the revived judgment’s enforcement did not suffer from prescription.
  • Petitioner’s and Respondents’ Arguments
    • Nilo Padre’s Arguments
      • Contended that the MTC lacked jurisdiction because:
        • The subject matter (recovery of real property) qualifies as a real action.
        • The assessed property value exceeded the P20,000 threshold.
      • Argued that the petition was filed timely by the mailing date rule.
      • Challenged the absence of the certificate of non-forum shopping and the claim of prescription.
    • Respondents’ (Badillo Family’s) Arguments
      • Argued that they properly filed a personal action for revival of judgment at the MTC pursuant to Section 2, Rule 4 of the Rules of Court.
      • Maintained that the prescriptive period should be reckoned from events later than the original RTC judgment (i.e., from when the defendants re-entered the property or when abandonment of prior proceedings occurred).
      • Asserted that any defects like the missing certificate of non-forum shopping were excusable given the circumstances.

Issues:

  • Jurisdictional Authority of the MTC
    • Whether the Municipal Trial Court has jurisdiction over the revival of judgment in a case involving real property where the assessed value exceeds the threshold of P20,000.00.
    • Whether an action for the enforcement of a dormant judgment, despite being characterized as a personal action, may be properly filed in the MTC instead of the RTC.
  • Timeliness and Procedural Issues
    • Whether Nilo Padre’s petition for certiorari with the RTC was timely filed, considering the rules on filing and the mailing date as the acceptance date.
    • Whether the absence of a certificate of non-forum shopping and the claim of prescription should affect the validity of the MTC’s proceedings.
  • Nature of the Relief Sought
    • Whether the relief sought by the Badillo family, through reviving a dormant judgment to oust possessors, constitutes a real action (ejectment-like action) or remains a personal action enforceable by the forum selected by the plaintiffs.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)
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