G.R. No. 214803 - Roldan vs. Spouses Barrios

On February 3, 2014, petitioner Alona G. Roldan filed Civil Case No. 9811 for judicial foreclosure of real estate mortgage against spouses Clarence I. Barrios and Anna Lee T. Barrios, and Rommel D. Matorres.
Petitioner alleged that on October 13, 2008, respondents Barrios borrowed ₱250,000 at 5% monthly interest, secured by a mortgage over Lot 5891-A-4 in Baybay, Makato, Aklan (assessed value ₱13,380; covered by OCT No. P-5561 pt.).
Respondents defaulted on payments starting February 2011; petitioner discovered a subsequent mortgage by Barrios in favor of Matorres dated June 11, 2012, which she alleged was in bad faith.

Spouses Barrios filed an Answer with Special and Affirmative Defenses, contesting the computation of the loan and invoking a pending petition for rehabilitation under Special Proceedings No. 9845 to suspend foreclosure.
Matorres filed an Answer with Special and Affirmative Defenses, admitted his mortgage, asserted a separate foreclosure case (Civil Case No. 9642) against Barrios, and prayed for damages and attorney’s fees.
On July 22, 2014, RTC Branch 6, Kalibo, Aklan dismissed both Civil Case Nos. 9642 and 9811 for lack of jurisdiction, holding that foreclosure is a real action and the assessed value (₱13,380) fell below the ₱20,000 threshold for RTC jurisdiction.
Petitioner and Matorres moved for reconsideration; on August 18 and September 1, 2014, the RTC denied both motions, reiterating that jurisdiction is determined by assessed value in real actions.
Petitioner filed a petition for certiorari before the Supreme Court, alleging grave abuse of discretion in dismissing her foreclosure case.

Whether the Regional Trial Court committed grave abuse of discretion in dismissing the foreclosure cases for lack of jurisdiction.

Whether an action for judicial foreclosure of mortgage is an action “incapable of pecuniary estimation” falling under the exclusive jurisdiction of the RTC.
Whether the assessed value of the mortgaged property determines the proper court for foreclosure proceedings.