Case Summary (G.R. No. 54470)
Key Dates
April 8, 1997 – MTC dismisses expropriation complaint for lack of jurisdiction
February 19 & 26, 1999 – RTC issues orders and writ of possession
March 29, 1999 – RTC (Branch 58) dismisses complaint for lack of jurisdiction
May 14, 1999 – RTC denies reconsideration
July 28, 1999 – Supreme Court denies petition for review as late; October 6, 1999 – petition reinstated
June 20, 2000 – Supreme Court decision
Applicable Law
1987 Philippine Constitution (post-1990 decision)
Batas Pambansa Blg. 129, Section 19(1) (RTC original jurisdiction over subject matter incapable of pecuniary estimation)
Republic Act No. 7691, Section 3(3) (MTC jurisdiction over real property actions below ₱20,000 assessed value)
1997 Rules of Court; relevant jurisprudence on expropriation and jurisdiction
Procedural Posture
Barangay San Roque filed an expropriation complaint in the MTC to acquire respondents’ property for public use. The MTC dismissed for lack of jurisdiction, citing exclusive RTC jurisdiction over eminent domain actions. Petitioner then filed in the RTC, which dismissed on the opposite ground—that the assessed value (₱1,740) placed it within MTC jurisdiction under RA 7691. Petitioner appealed to the Supreme Court via petition for certiorari.
Central Issue
Which court—MTC or RTC—has original jurisdiction over an eminent domain suit when the property’s assessed value is below ₱20,000?
Rationale of the RTCs
MTC: Eminent domain is an exercise of sovereign power, not a real property action, and thus falls exclusively under RTC jurisdiction.
RTC: Expropriation affects title or possession of real property; assessed value under ₱20,000 places the case within MTC’s exclusive original jurisdiction under RA 7691.
Supreme Court’s Jurisdictional Framework
Under BP 129, Section 19(1), RTCs have exclusive original jurisdiction over civil actions “in which the subject of the litigation is incapable of pecuniary estimation.” Jurisdictional classification hinges on the nature of the principal relief sought: if primarily for recovery of money, jurisdiction depends on amount; if the claim is incidental to another principal remedy, the action is deemed incapable of pecuniary estimation and vested in courts of first instance (now RTCs).
Nature of Expropriation Proceedings
Expropriation entails two phases:
- Determination of authority and propriety of the sovereign’s exercise of eminent domain, culminating in an order of c
Case Syllabus (G.R. No. 54470)
Procedural History
- Petitioner filed an expropriation complaint in the Municipal Trial Court of Talisay, Cebu (Branch 1).
- MTC dismissed the complaint for lack of jurisdiction on April 8, 1997, ruling that eminent domain actions fall exclusively within the jurisdiction of the Regional Trial Court.
- Petitioner then filed the same complaint before the Regional Trial Court of Cebu City (Branch 58).
- RTC dismissed the complaint on March 29, 1999, for lack of jurisdiction, reasoning that the assessed value of the property (P1,740) placed it within the MTC’s exclusive jurisdiction.
- Petitioner’s motion for reconsideration before the RTC was denied on May 14, 1999.
- Petitioner sought relief from the Supreme Court via a Petition for Review on Certiorari, initially denied as filed out of time, but later reinstated on October 6, 1999.
- Case submitted for decision on March 16, 2000; decision promulgated June 20, 2000.
Facts
- The subject property is owned by the respondents, heirs of Francisco Pastor.
- Barangay San Roque, Talisay, Cebu (petitioner) sought to expropriate the land for public use, invoking the right of eminent domain.
- The land’s assessed value per current Tax Declaration was One Thousand Seven Hundred Forty Pesos (P1,740.00).
- The government entity did not dispute the respondents’ title or possession but asserted its sovereign power to appropriate property for public benefit.
Issue
- Which court—Municipal Trial Court (MTC) or Regional Trial Court (RTC)—has jurisdiction over an eminent domain or expropriation suit when the assessed value of the property is below Twenty Thousand Pesos (P20,000)?
Petitioner’s Arguments
- Relied on Section 19