Case Summary (G.R. No. 45685)
Land Description and Tax Declarations
– Total area: approximately 265,342 sq. m.
– Petitioners’ tax declarations (issued 1990) reflect assessed value: P54,370.00.
– Respondents’ tax declarations correspond to titled portions under their OCT (FP) numbers.
Procedural History
- Petitioners filed Reconveyance of Ownership or Possession with Damages (Civil Case No. 939) before MTC Bolinao on February 14, 2000.
- Respondents answered, denied allegations, asserted their titles’ indefeasibility, and counterclaimed for fees and damages.
- MTC tried the case on agreed issues: superior right, ownership, fraud in patent issuance, prior possession, entitlement to damages.
MTC Decision
Date: November 9, 2001
Outcome: Complaint dismissed. Defendants (respondents) declared lawful owners and possessors under OCT (FP) Nos. 15818–15820, 15754–15756. Plaintiffs (petitioners) ordered to pay P50,000 attorney’s fees and costs.
RTC Decision on Appeal
Date: June 14, 2002
Outcome: MTC Decision reversed in toto. Free patents declared void; respondents ordered to reconvey entire titled areas to petitioners. Damages awarded (P20,000 moral, P20,000 exemplary, P5,000 actual each). Petitioners directed to divide reconveyed land among themselves.
Court of Appeals Decision
Date: May 29, 2007 (Resolution denied August 22, 2007)
Ground: Lack of jurisdiction both in MTC and RTC.
Ruling: Annulled and set aside MTC and RTC decisions. Held that:
- MTC lacked jurisdiction (assessed value > P20,000).
- Assuming RTC had jurisdiction, it could not void four-year-old free patents due to Torrens system’s indefeasibility and incontrovertibility after one year from registration.
Issue on Jurisdiction
Whether the CA gravely erred in annulling the RTC Decision for lack of jurisdiction despite the RTC’s appellate and original jurisdiction over real estate actions involving land valued above P20,000.
Applicable Law
– 1987 Constitution (property and judicial authority)
– B.P. Blg. 129, Sec. 19(2): RTC exclusive original jurisdiction in real property actions with assessed value > P20,000.
– B.P. Blg. 129, Sec. 22: RTC appellate jurisdiction over all MTC decisions.
– Rule 40, Sec. 8, Rules of Court: RTC may decide on merits where lower court tried case without jurisdiction.
– Rule 45, Sec. 1, Rules of Court: Review on certiorari limited to questions of law.
Supreme Court Ruling
- Jurisdiction: Petitioners’ complaint alleged assessed value > P20,000; RTC had original jurisdiction. MTC lacked jurisdiction but its decision could be reviewed by the RTC under Rule 40, Sec. 8(2).
- Appellate Authority: RTC possessed appellate jurisdiction over MTC decisions regardless of amount in controversy (Sec. 22, B
Case Syllabus (G.R. No. 45685)
Antecedent Facts
- Petitioners claim ownership and uninterrupted possession since 1967 of portions of a subdivided parcel (Lot No. 7303, Cad. 559-D) in Barangay Patar, Bolinao, Pangasinan, totaling about 265,342 sqm.
- They discovered Free Patent Titles over the same lot issued in favor of respondents (except Eugenio Santiago, Sr.) allegedly obtained through manipulation, misrepresentation, fraud and deceit.
- Petitioners allege thirty years of open, continuous, exclusive possession before issuance of the patents, converting the land into private property and depriving the Bureau of Lands of jurisdiction.
- Attached tax declarations support petitioners’ claims; prayers include declaration as absolute owners, reconveyance of the entire lot, and award of actual, moral, and exemplary damages plus litigation expenses.
- Respondents denied material allegations, insisted on regular acquisition of titled parcels via duly registered Deeds of Sale (1991–1992) and supported by Original Certificates of Title (Free Patent Nos. 15754–15756; 15818–15820) and tax declarations; they counterclaimed for attorney’s fees, damages, and costs.
Municipal Trial Court Proceedings
- Respondents challenged MTC’s jurisdiction, citing B.P. Blg. 129 § 33(3) and the assessed value over ₱20,000.
- Parties jointly framed five issues: superior right, lawful ownership, fraud in patent acquisition, prior possession, and entitlement to damages.
- On November 9, 2001, MTC (Civil Case No. 939) dismissed petitioners’ complaint, declared respondents lawful owners of Lot 7303 under six titles, and awarded ₱50,000 for attorney’s fees and litigation expenses plus costs.
Regional Trial Court Proceedings
- Petitioners appealed to RTC, Branch 54, Alam