Title
Quinagoran vs. Court of Appeals
Case
G.R. No. 155179
Decision Date
Aug 24, 2007
Heirs claimed co-ownership of land; petitioner occupied portion, asserting ownership. SC ruled RTC lacked jurisdiction due to unalleged assessed value, nullifying proceedings.
A

Case Digest (G.R. No. 198587)

Facts:

  • Parties and capacities
    • Victorino Quinagoran, petitioner, defendant in the trial court action.
    • Heirs of Juan dela Cruz, represented by Senen dela Cruz, respondents, plaintiffs in the trial court action.
  • Description of the subject property and ownership claim
    • The disputed parcel is described as Lot No. 1807, Pls-149 (FV-7403), Centro, Piat, Cagayan, containing 13,100 square meters, covered by Original Certificate of Title No. P-1670.
    • Respondents alleged they are the direct and legitimate heirs of the late Juan dela Cruz and inherited the parcel.
    • Respondents alleged that a house occupied by petitioner stands on the north-west portion of the lot and occupies approximately 400 square meters.
  • Events leading to the complaint
    • Petitioner allegedly erected or occupied the house in the mid-1970s by tolerance of respondents.
    • In 1993 respondents demanded removal of the house to construct a commercial building; petitioner refused and asserted ownership over the portion.
    • Respondents alleged repeated demands were ignored and that they suffered damages; they prayed for reconveyance and surrender of the disputed 400 sq m, P5,000.00 monthly until vacated, attorney’s fees of P20,000.00, costs, and other reliefs.
  • Petitioner's jurisdictional contention and evidentiary allegations
    • Petitioner moved to dismiss for lack of jurisdiction, invoking R.A. No. 7691 and asserting that municipal courts have exclusive jurisdiction when the assessed value of the property does not exceed P20,000.00 outside Metro Manila.
    • Petitioner argued that the assessed value of an adjacent 346 sq m lot was P1,730.00 and that the assessed value of the contested portion therefore would not exceed that amount.
    • Petitioner later submitted a tax declaration copy to the Court of Appeals purporting to show an assessed value of P551.00 for Lot No. 1807.
  • Trial court proceedings and rulings
    • Respondents filed a Complaint for Recovery of Portion of Registered Land with Compensation and Damages before the Regional Trial Court (RTC), Branch XI of Tuao, Cagayan, docketed as Civil Case No. 240-T, filed October 27, 1994.
    • RTC denied petitioner’s Motion to Dismiss by Order dated November 11, 1999, holding the action to be in the nature of an *accion publiciana* and that jurisdiction lay with the RTC regardless of the value of the property.
    • RTC denied petitioner’s Motion for Reconsideration.
  • Proceedings in the Court of Appeals
    • Petitioner filed a Petition for Certiorari and Prohibition before the Court of Appeals (CA).
    • CA rendered Decision dated May 27, 2002 in CA-GR SP No. 60443 denying relief and affirming the RTC,...(Subscriber-Only)

Issues:

  • Primary jurisdictional questions
    • Whether the RTC had original and exclusive jurisdiction over the respondents’ action for recovery of portion of registered land regardless of the assessed value of the property.
    • Whether a complaint invoking recovery of possession or title must allege the assessed value of the property to establish which court has jurisdiction under R.A. No. 7691.
  • Ancillary legal questions
    • Whether the courts may take judicial notice of the assessed or market ...(Subscriber-Only)

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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