G.R. No. 205998 - Siy vs. Tomlin

In July 2011, petitioner William Anghian Siy filed a Complaint for Recovery of Possession with Prayer for Replevin in RTC-Quezon City Branch 224 against Frankie Domanog Ong, Chris Centeno, John Co Chua, and respondent Alvin Tomlin, seeking the return of a 2007 Range Rover (Plate ZMG 272), attorney’s fees of ₱100,000, and costs.
Siy alleged he bought the vehicle from Alberto Lopez III on July 22, 2009, then entrusted it in 2010 to Ong (a second-hand car dealer) to sell; Ong failed to remit the proceeds or return the vehicle, which was subsequently transferred to Chua and later impounded by the PNP-Highway Patrol Group when Tomlin attempted to process a clearance.
On July 29, 2011, the RTC issued a writ of replevin upon Siy’s posting of an ₱8 million bond; the sheriff seized the vehicle.

On August 17, 2011, Tomlin filed an Omnibus Motion to quash the writ, dismiss the complaint, and return the vehicle—claiming (a) he is the registered owner (registration dated March 7, 2011), (b) incorrect docket fees due to undervaluation, (c) defective complaint for failure to allege Rule 60 requirements, and (d) procedural irregularities in service of the writ.
The RTC denied the motion on November 21, 2011 (and denied reconsideration), ruling that Tomlin’s remedy was to post a counterbond, that ownership and sufficiency of allegations were to be tried on the merits, and that undervaluation did not divest jurisdiction.

Tomlin petitioned the Court of Appeals for certiorari (CA-G.R. SP No. 124967) reiterating the grounds of wrong docket fees, defective complaint, improper service, and lack of jurisdiction during the court’s inventory period.
On October 9, 2012, the CA granted the petition: it reversed and set aside the RTC orders; dismissed Civil Case No. Q-11-69644 for lack of jurisdiction due to misdeclaration of the vehicle’s value (₱2 million vs. actual ~₱4.5–5 million) and non-compliance with Rule 60 Section 2; found the writ improperly served; and ordered the vehicle returned to the PNP-HPG.
On February 19, 2013, the CA denied Siy’s motion for reconsideration.

Siy filed a Petition for Review on Certiorari before the Supreme Court, assailing the CA Decision and Resolution.
The petition raised three assignments of error: (I) jurisdiction of the RTC, (II) defective allegations under Rule 60, Sections 2 & 4, and (III) proper implementation of the writ of replevin.
On November 10, 2014, the Supreme Court resolved to give due course to the petition.

Did the trial court acquire jurisdiction over the replevin case?
Did petitioner fail to allege all material facts in the complaint and affidavit as required under Rule 60, Sections 2 & 4?
Was the writ of replevin properly implemented by the sheriff’s service upon respondent?