A.M. No. RTJ-02-1693 - Poso vs. Mijares

Case Summary (A.M. No. RTJ-02-1693)

Allegations and relief in the complaint filed by respondents

Respondents alleged that their deceased father, Roman Tapulao, was the registered owner of the parcel (Lot No. 1072, Pls‑492‑D, embraced under OCT No. P‑9331) and that the lot was declared for taxation with an assessed value of Php22,070.00 as shown by the municipal tax declaration. They asserted respondents’ ownership, paid realty taxes, and averred that a relocation survey showed petitioners occupying portions of the lot; despite demands, petitioners refused to vacate. Relief sought was recovery of possession and damages.

Petitioners’ factual assertions and defense at trial

Petitioners asserted that the original owner was Felipe PeAa who, in 1954, ceded possession over half a hectare to petitioner Joaquin; Joaquin had been in open and exclusive possession since then. Petitioners claimed that an adjacent lot sold to Roman Tapulao was mistakenly included in OCT No. P‑9331 and that Roman and his wife acknowledged the error in an affidavit dated April 2, 1976, promising to respect Joaquin’s ownership of that specific portion. Petitioners pleaded affirmative relief in their Answer, including dismissal of the complaint and an order for transfer/registration in their favor, plus damages.

Pre‑trial and ex parte evidence presentation

The case experienced multiple pre‑trial resets. On January 30, 2014, petitioners and their counsel failed to appear; respondents moved to present evidence ex parte, which the trial court allowed. The trial court thereafter received evidence and proceeded to judgment.

Trial court judgment and remedies awarded

The RTC rendered judgment in favor of plaintiffs, declaring them rightful owners of the property covered by OCT No. P‑9331 (area stated as 18,512 square meters), ordering the defendants to vacate and surrender possession of the portion they occupied, and awarding actual damages of Php4,131.00 for expenses incurred in filing the case. The RTC denied petitioners’ subsequent motion for reconsideration, noting the complaint’s allegation of assessed value of Php22,070.00 which placed the action within the RTC’s jurisdiction.

Court of Appeals’ disposition

The Court of Appeals affirmed the RTC, holding that respondents sufficiently proved ownership of the lot and the portion occupied by petitioners. The CA agreed that the RTC properly exercised jurisdiction because the property’s alleged assessed value exceeded Php20,000.00, falling within RTC jurisdiction under BP 129 as amended.

Petitioners’ principal argument on appeal to the Supreme Court

Petitioners argued that jurisdiction should be determined by the assessed value of only the portion actually in dispute (allegedly 6,804 square meters), which they computed to have an assessed value of Php8,111.72 — an amount within the jurisdictional threshold of the Municipal Trial Courts (MTCs). They maintained that the RTC therefore lacked subject-matter jurisdiction.

Legal standard on subject‑matter jurisdiction applied by the court

The Court reiterated that jurisdiction is the court’s power to hear and decide a case and that subject‑matter jurisdiction is conferred by law and is determined by the material allegations of the complaint and the relief sought. The Court cited Sections 19 and 33 of BP 129 (as amended by RA 7691) delineating RTC jurisdiction for civil actions involving title to or possession of real property where the assessed value exceeds Php20,000.00 and MTC jurisdiction when assessed value does not exceed Php20,000.00.

Application of the legal standard to the complaint’s allegations

The Court observed that the complaint explicitly alleged the assessed value of the entire lot as Php22,070.00 per the municipal tax declaration, and that under the statutory scheme such an allegation placed the action within the RTC’s exclusive original jurisdiction. The Court held that the subject‑matter jurisdiction must be determined from the complaint’s allegations and relief sought, and that respondents’ pleading cannot be unilaterally redefined by petitioners.

Rejection of petitioners’ contention regarding partial‑lot valuation

The Court found that petitioners’ argument — that only the assessed value of the portion they occupy should determine jurisdiction — was irrelevant because the com

Case Syllabus (A.M. No. RTJ-02-1693)

Citation and Court

Reported at 855 Phil. 571, Second Division.
G.R. No. 227482.
Decision promulgated July 01, 2019.
Decision authored by Justice Lazaro‑Javier with concurrence by Carpio (Chairperson), Perlas‑Bernabe, Caguioa, and J. Reyes, Jr.

The Case (Nature and Relief Sought)

Petition for Review on Certiorari seeking reversal of the Court of Appeals Decision dated September 30, 2016 (CA‑G.R. CV No. 104126).
The Court of Appeals had affirmed the Regional Trial Court (RTC), Branch 1, Tuguegarao City, Cagayan Judgment dated August 1, 2014 in Civil Case No. 7899.
Trial court had granted plaintiffs’ Complaint for Recovery of Possession and Damages, declared respondents as rightful owners of the subject property, ordered petitioners to vacate the portion they occupied, and awarded actual damages of P4,131.00.

Parties

Petitioners: Joaquin Berbano, Trinidad Berbano, and Melchor Berbano.
Respondents: Heirs of Roman Tapulao — Albert D. Tapulao (also referred to as Albert T. Tapulao), Danilo D. Tapulao (also referred to as Danny D. Tapulao), Marieta Tapulao‑Reyes, Linda Tapulao‑Ramirez, and Josefina Tapulao‑Dacanay, represented by attorney‑in‑fact Josefina Tapulao‑Dacanay.
Original registered owner alleged: Roman Tapulao (deceased) and his wife Catalina Casabar‑Tapulao (deceased).

Material Facts

Respondents alleged that Roman Tapulao was the registered owner of Lot No. 1072, PLS‑492‑D, located in Taguing, Baggao, Cagayan, embraced under Original Certificate of Title (OCT) No. P‑9331.
The parcel was declared for taxation and carried an assessed value of Twenty Two Thousand and Seventy Pesos (Php22,070.00), as evidenced by Tax Declaration No. 03‑06042‑00175 issued by the Municipal Assessor of Baggao, Cagayan.
Following the deaths of Roman and Catalina Tapulao, respondents caused a relocation survey which revealed that petitioners occupied portions of the lot.
Respondents made several demands for vacatur which petitioners allegedly refused.
Petitioners asserted in their Answer that the original owner was Felipe PeAa and that in 1954 Felipe PeAa ceded possession of half a hectare of the lot to Joaquin Berbano, that Joaquin had been in open and exclusive possession since then, and that a subsequent registration of an adjacent lot in favor of Roman Tapulao mistakenly included Joaquin’s lot.
Petitioners asserted that Roman and Catalina Tapulao acknowledged the survey error by an Affidavit dated April 2, 1976, promising to respect Joaquin’s ownership of that portion.
The entire lot’s stated area was 18,512 square meters; petitioners later contended that the real subject matter was only 6,804 square meters (the portion they occupied).

Proceedings Before the Trial Court (RTC)

Respondents filed a Complaint for Recovery of Possession and Damages against petitioners.
The case underwent pre‑trial which was reset eight (8) consecutive times for varying reasons.
On January 30, 2014, petitioners and their counsel failed to appear at pre‑trial; respondents moved to present evidence ex parte, which the trial court allowed.
After hearing, the RTC rendered judgment on August 1, 2014 in favor of respondents.

Trial Court Judgment (August 1, 2014)

The RTC declared plaintiffs/respondents as the rightful and legal owners of the subject property covered by OCT No. P‑9331 (Lot No. 1072, Taguing, Baggao, Cagayan), with an area of 18,512 square meters.
Ordered defendants/petitioners to vacate the portion they occupied and surrender possession to plaintiffs.
Ordered defendants to pay plaintiffs P4,131.00 as actual damages (expenses incurred in filing the case).
No pronouncement as to costs.
In their Answer, petitioners had sought dismissal of the case, an order for plaintiffs to execute documents to transfer and register the lot in the name of defendants, and awards of actual, moral and exemplary damages; they thereby sought affirmative relief below.

Motion for Reconsideration at Trial Court

For the first time in motion for reconsideration, petitioners raised lack of jurisdiction: they argued that val