Case Digest (G.R. No. 246332) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In 2005, Spouses Claudio and Carmencita Trayvilla (petitioners) filed Civil Case No. 4633-2K5 before the Regional Trial Court (RTC), Branch 18, Pagadian City, against Bernardo Sejas and later impleaded Juvy Paglinawan (respondents) represented by Jessie Paglinawan. The petitioners alleged that Sejas, registered owner of a 434-sqm parcel in Tukuran, Zamboanga del Sur under Transfer Certificate of Title No. T-8,337, sold the property to them in 1982 via a private handwritten instrument, after which they took possession, built a residence, and continued to occupy it. They lodged an adverse claim annotation when Sejas attempted to reassert ownership. Their original complaint for specific performance and damages sought a final deed of sale and P30,000 attorney’s fees plus P1,500 per appearance. After discovering that Sejas had sold the same land to Paglinawan, who obtained TCT No. T-46,627, petitioners filed an Amended Complaint adding claims for reconveyance, cancellation of TCT T-4 Case Digest (G.R. No. 246332) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Original Complaint (2005)
- Petitioners Claudio and Carmencita Trayvilla alleged they purchased a 434-sqm parcel in Tukuran, Zamboanga del Sur (TCT T-8,337) from respondent Bernardo Sejas in 1982 by private document, took possession, built and resided in a house thereon.
- They sued Sejas for specific performance and damages, praying that he execute a final deed of sale and pay P30,000 attorney’s fees plus P1,500 per appearance.
- Amended Complaint and Trial Court Proceedings
- Petitioners impleaded respondent Juvy Paglinawan, alleging Sejas sold the same property to her and she caused cancellation of TCT T-8,337 and issuance of TCT T-46,627 in her name. They prayed for reconveyance, cancellation of Paglinawan’s title, P50,000 moral damages, and the same attorney’s fees.
- They did not pay additional docket fees for moral damages or new causes of action. Respondents moved to dismiss for lack of jurisdiction (fee deficiency) and prescription. The RTC denied the motion in orders dated September 3, 2007 and February 21, 2008, holding the suit was one for specific performance (incapable of pecuniary estimation).
- Proceedings Before the Court of Appeals
- Respondents filed a petition for certiorari in CA-G.R. SP No. 02315. On November 29, 2011, the CA nullified the RTC orders, ruled the suit was a real action (affecting title), and dismissed the case for non-payment of correct docket fees.
- On November 19, 2012, the CA denied petitioners’ motion for reconsideration.
Issues:
- Docket Fees and Jurisdiction
- Did the CA correctly dismiss the complaint for non-payment of correct docket fees due to failure to allege the fair market or stated value of the property?
- Effect of the Amended Complaint
- Did filing the Amended Complaint divest the RTC of jurisdiction previously acquired upon the original complaint for specific performance?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)