Case Summary (G.R. No. 187696)
Antecedent Facts and Complaint
Petitioner Filomena Cabling alleged ownership of a 125-square-meter parcel of land and claimed that respondent Rodrigo Dangcalan encroached upon it by constructing a perimeter fence that extended into her property. Despite knowing the property boundaries, Dangcalan allegedly built the fence unlawfully after purchasing adjoining land from petitioner’s brother, Gerardo Montajes. After unsuccessful attempts to demand removal of the fence and a failed mediation through the Lupong Tagapamayapa, petitioner filed a Complaint for recovery of possession and damages before the 2nd Municipal Circuit Trial Court (MCTC) in May 2001.
Respondent’s Defense and Prescription Claim
Respondent denied any encroachment and asserted prescription as an affirmative defense, claiming that the perimeter fence and house were constructed in 1987 with petitioner’s knowledge, as she observed part of the construction. Therefore, respondent argued the 10-year period for acquisitive prescription under Article 1134 of the New Civil Code had already elapsed when petitioner filed the complaint in 2001.
MCTC Decision
The MCTC found in favor of petitioner, relying on a sketch plan and court-appointed commissioner's testimony, confirming a 13-square-meter encroachment. The court ruled that the respondent was a builder in bad faith for failing to verify property boundaries before constructing the fence. The decision ordered respondent to surrender possession of the encroached portion, pay monthly rental from demand to vacation, and compensate petitioner for moral, exemplary, and actual damages, as well as costs of suit, in accordance with Article 448 of the Civil Code.
RTC Decision on Appeal
The Regional Trial Court (RTC), acting on appeal, reversed the MCTC ruling. It discredited the commissioner’s sketch plan due to the absence of a formal report and unclear survey basis. The RTC prioritized the affirmative defense of prescription raised by the respondent, holding that the action was already barred and that respondent built the fence in good faith in 1987. The RTC did not address damages or costs, focusing on prescription and good faith.
Court of Appeals Ruling
Upon petitioner’s appeal to the Court of Appeals (CA), the CA declined to rule on the substantive questions. Instead, it declared both the MCTC and RTC decisions void for lack of jurisdiction, classifying the complaint as an accion publiciana, a plenary action for recovery of possession which the CA maintained was exclusively under the jurisdiction of the RTC. Consequently, the CA dismissed the complaint without prejudice to refiling, invalidating prior proceedings and decisions. Petitioner’s motion for reconsideration was denied.
Legal Issue Presented
Whether the CA erred in declaring the MCTC and RTC decisions void for lack of jurisdiction on the ground that the MCTC had no jurisdiction over the complaint for accion publiciana.
Jurisdictional Framework and Applicable Law
Under Republic Act No. 7691 amending B.P. Blg. 129, the jurisdiction over civil cases involving title or possession of real property depends on the assessed value of the property:
- RTC has exclusive original jurisdiction if the assessed value exceeds P20,000 outside Metro Manila (P50,000 in Metro Manila).
- Municipal Trial Courts, Municipal Circuit Trial Courts, and Metropolitan Trial Courts have exclusive jurisdiction if the assessed value does not exceed P20,000 (P50,000 in Metro Manila), exclusive of interests, damages, and costs.
The action for recovery of possession or accion publiciana falls within this framework.
Supreme Court’s Ruling on Jurisdiction
The Supreme Court held that it is no longer correct to assert that all cases for recovery of possession (accion publiciana) fall under RTC jurisdiction regardless of value. The 1994 amendment (RA 7691) clearly grants jurisdiction to municipal courts over cases involving property with assessed value below P20,000 outside Metro Manila. Since the property involved was assessed at P2,100, the MCTC properly exercised jurisdiction.
The Court emphasized that jurisdiction is determined by facts alleged in the complaint, including the assessed value, and not by the substantive merits or outcome of the case. It noted precedents confirming that if the complaint alleges a qualifying assessed value, jurisdiction lies with the appropriate municipal trial court.
Effect on the Decisions of Lower Courts
The Supreme Court ruled that the CA erred in nullifying the MCTC and RTC decisions for lack of jurisdiction. The MCTC’s exercise of exclusive original jurisdiction was proper, and the RTC’s role as appellate court on the MCTC’s decision was likewise correctly assumed under the law. Neither decision could be declared void. Accordingly, the complaint should not have been dismissed outright by the CA.
Substantive Issues and Scope of the Supreme Court’s Review
While petitioner challenged the RTC’s factual findings on good faith, prescription, and laches, the Supreme Court clarified that these are questions of fact, not legal questions, and therefore beyond
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Case Syllabus (G.R. No. 187696)
Background and Antecedent Facts
- The case originated from a Complaint for recovery of possession and damages filed by Filomena Cabling (petitioner) against Rodrigo Dangcalan (respondent).
- The dispute arose from respondent’s alleged encroachment on petitioner’s 125-square-meter parcel of land located in San Vicente, Malitbog, Southern Leyte (Lot No. 5056, assessed value P2,100).
- Respondent purchased an adjoining parcel from petitioner’s brother, Gerardo Montajes.
- Despite known boundary lines, respondent constructed a perimeter fence that allegedly encroached on petitioner’s property.
- After several demands and a failed dispute resolution conference before the Lupong Tagapamayapa, petitioner filed the Complaint before the 2nd Municipal Circuit Trial Court (MCTC) in May 2001.
- Respondent denied alleged encroachment and asserted prescription as an affirmative defense.
- He claimed construction began in 1987 with petitioner’s knowledge and consent, and that the suit filed in 2001 was barred by the 10-year period for acquisitive prescription under Article 1134, New Civil Code.
Decisions by the Municipal Circuit Trial Court and Regional Trial Court
- The MCTC ruled in favor of petitioner, based on a commissioner’s sketch plan and testimony, finding respondent’s fence encroached 13 square meters.
- Respondent was declared a builder in bad faith for failing to verify property boundaries.
- The MCTC ordered respondent to surrender possession of the encroached portion, pay monthly rental, moral, exemplary, and actual damages, and costs of suit.
- On appeal, the Regional Trial Court (RTC) reversed the MCTC ruling.
- The RTC rejected the commissioner’s sketch plan due to lack of accompanying report and unclear survey basis.
- The RTC held that the MCTC should have first addressed prescription because respondent raised it timely through an amended answer.
- The RTC declared the complaint barred by prescription and laches, and found respondent a builder in good faith.
- No damages or costs were awarded by the RTC.
Court of Appeals Ruling and Jurisdiction Issue
- Petitioner appealed the RTC ruling to the Court of Appeals (CA), raising three primary issues:
- Whether the trial court erred in dismissing the complaint based on acquisitive and extinctive prescription.
- Whether the trial court erred in declaring the complaint barred by laches.
- Whether the trial court erred in finding respondent a builder in good faith.
- Instead of ruling on these, the CA dismissed the petition and declared both MCTC and RTC decisions null and void for lack of jurisdiction.
- CA held the MCTC lacked jurisdiction because the complaint was an accion publiciana, a plenary action for recovery of possession which exclusively falls under the RTC’s original jurisdiction.
- The CA ordered dismissal of the complaint without prejudice to filing a new case before the RTC.