Facts:

• Spouses Tomas Libiran and Potenciana Feliciano (deceased), represented by Roning Santos, obtained multiple loans from Elisan Credit Corporation.
• The initial loan of PHP200,000.00 was secured by a promissory note and a real estate mortgage over a parcel of land in Bulacan, covered by TCT No. T-405042 (M).
• Subsequent loans were taken on December 9, 2005 (PHP609,000.00), March 9, 2006 (PHP118,000.00), and June 15, 2006 (PHP474,000.00).
• Partial payments were made, but significant amounts remained unpaid.
• Elisan filed a complaint for judicial foreclosure of the mortgage with the RTC of Quezon City due to the spouses' failure to settle their obligations totaling PHP885,380.00, including interests and penalties.
• The Spouses Libiran denied the loans, claimed improper venue, and alleged that they were made to sign blank documents and that the mortgage was for their daughter and son-in-law's loan, which had been paid.
• The RTC ruled in favor of Elisan, ordering the spouses to pay the outstanding amounts and dismissing their counterclaims.
• The CA affirmed the RTC's decision but reduced the interest rate from 26% to 12% per annum.
• The Spouses Libiran filed a petition with the Supreme Court, arguing improper venue, lack of jurisdiction due to the failure to allege the assessed value of the property, and other defenses.

Issue:

• (Unlock)

Ruling:

1. The Supreme Court ruled that the RTC of Quezon City did not have jurisdiction over the complaint for judicial foreclosure of mortgage.
2. The Supreme Court did not find it necessary to discuss the issue of proper venue in detail due to the jurisdictional ruling.
3. The Supreme Cou...(Unlock)

Ratio:

• Jurisdiction over the subject matter is conferred by law and determined by the allegations in the complaint.
• The complaint for judicial foreclosure of mortgage is a real action, and the assessed value of the property determines the court's jurisdiction.
• The failure to allege the...continue reading