Title
De Ungria vs. Court of Appeals
Case
G.R. No. 165777
Decision Date
Jul 25, 2011
Dispute over land ownership involving alleged forged documents; RTC and CA ruled in favor of respondents, rejecting defenses of laches and prescription.
motion to dismiss
complaint
ownership

Case Summary (G.R. No. 165777)

Factual Background

Respondents alleged that the subject parcel was originally registered in the name of the late Fernando Castor, husband of Rosario Dideles Vda. de Castor, and that the family held tax declaration No. 15272 with an assessed value of P12,780.00. Respondents averred that they only learned in August 1999 of a Deed of Transfer of Rights and Interest dated October 3, 1960, by which Fernando allegedly transferred his rights to Eugenio de Ungria, and an Affidavit of Relinquishment dated November 23, 1960 by which Eugenio purportedly relinquished rights in favor of Ceferina de Ungria. Respondents alleged forgery of Fernando’s signature on the Deed and that the Affidavit derived from a simulated transaction. They prayed for declaration as absolute owners, annulment of the documents, reconveyance of Rosario’s conjugal one-half share, recovery of possession and damages, and redemption in the alternative. Respondents also alleged rentals of P2,000.00 per hectare per crop and asserted amounts of actual and compensatory damages to be proved at trial.

Trial Court Proceedings

On August 26, 1999, respondents filed their complaint with the RTC. Ceferina de Ungria moved to dismiss (Ex-Abundante Ad Cautelam) on grounds that the sale to Eugenio was valid, that the action was barred by extraordinary acquisitive prescription and laches, and that plaintiffs failed to state a cause of action or to resort to barangay conciliation. An addendum challenged plaintiffs’ legal capacity and the sufficiency of filing fees. The RTC denied the motion to dismiss in an Order dated November 19, 1999, reasoning that Rosario’s claim to a conjugal share raised issues properly triable. Petitioner’s motion for reconsideration was denied on February 4, 2000.

RTC Orders and Clarifications on Filing Fees

Petitioner thereafter filed an omnibus motion and the plaintiffs sought allowance to proceed as indigent litigants. By Order dated March 8, 2000 the RTC denied the omnibus motion but instructed the Clerk of Court to assess any deficiency in filing fees after hearing and to treat additional fees as lien on any judgment. A Clarificatory Order dated March 30, 2000 reiterated that, since hearing had not yet occurred, plaintiffs could not yet fix damages and that any additional filing fee deficiency would be a lien on judgment. The RTC again denied reconsideration on May 31, 2000. The Legal Fees Form in the record reflected payment of P400.00 to the Clerk of Court together with other fees.

The Parties’ Contentions on Appeal

Petitioner contended that the RTC lacked jurisdiction because respondents failed to specify the amount of damages in the prayer as required by SC Circular No. 7, and because respondents did not pay the correct docket fees. She further maintained that her possession since 1952 through predecessor-in-interest ripened into ownership by extraordinary acquisitive prescription, and that respondents’ claim was barred by laches. Respondents maintained that they were registered owners under a Torrens title and that the disputed Deed and Affidavit were void for forgery and simulation. They argued that their alternative reliefs sought annulment and reconveyance, remedies not susceptible of pecuniary estimation, and that they paid the required filing fees.

Court of Appeals’ Ruling

The Court of Appeals dismissed petitioner’s certiorari petition in a decision dated May 26, 2004 and denied reconsideration on September 17, 2004. The CA held that SC Circular No. 7 did not apply where the amount of damages was immaterial to jurisdiction and that the circular governs only cases where the amount claimed determines jurisdiction, citing Tacay v. RTC of Tagum, Davao del Norte. The CA found that respondents had paid the assessed docket fees and that the RTC thus acquired jurisdiction. The CA endorsed the RTC’s approach that any deficiency in filing fee to be assessed after hearing would constitute a lien on the judgment, citing Sun Insurance Office, Ltd. v. Asuncion. The CA further held that defenses of acquisitive prescription and laches were unavailing against a registered owner, noting that the subject property was covered by a Torrens title (OCT No. V-19556).

Issues Presented to the Supreme Court

Petitioner framed the issues as whether the Court of Appeals erred in not finding that the RTC committed grave abuse of discretion by denying the motion to dismiss despite respondents’ nonpayment of the correct docket fees, and whether the action was barred by laches and extraordinary acquisitive prescription.

The Supreme Court’s Disposition

The Court denied the petition for review and affirmed the Court of Appeals. The Court first determined jurisdiction. It applied Batas Pambansa Blg. 129, as amended by Republic Act No. 7691, and examined Sections 19 and 33 governing the jurisdictional allocation between Regional Trial Courts and lower courts. The Court invoked the rule from Singson v. Isabela Sawmill that the nature of the principal action governs whether the subject is capable of pecuniary estimation. Because the complaint joined a real action for recovery of possession with alternative causes seeking annulment of instruments and reconveyance, remedies not susceptible of pecuniary estimation, the Court concluded that the RTC had exclusive jurisdiction. The Court then applied Rule 141, Sec. 7(b)(1) and held that where the subject of litigation cannot be estimated in money, the filing fee is P400.00. Having found proof of payment of P400.00 in the record, the Court held that jurisdiction vested in the RTC and once acquired was not lost.

Legal Basis and Reasoning on Filing Fees and SC Circular No. 7

The Court reconciled SC Circular No. 7 and its Manchester predecessor with later jurisprudence. It reaffirmed that the acquisition of jurisdiction requires payment of the prescribed docket fee and cited Sun Insurance Office, Ltd. v. Asuncion for the principles that the court may allow payment within a reasonable time and that additional fees for claims left to determination by the court constitute a lien on the judgment enforceable by the Clerk of Court. The Court relied on Heirs of Bertuldo Hinog v. Melicor to the effect that Sun Insurance effectively modified SC Circular No. 7 as to unliquidated damages and that filing fees for damages not susceptible of estimation may be treated as a lien on any judgment. Applying those principles, the Court found no reversible error in the RTC’s Clarificatory Order that additional filing fees, if proven insufficient after hearing, would be a lien on the judgment.

Legal Basis and Reasoning on Prescription and Laches

On the defenses of extraordinary acquisitive prescription and lache

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