Case Summary (G.R. No. 196874)
Key Dates and Applicable Law
Relevant procedural milestones include the Regional Trial Court (RTC) Decision (Branch 32, Lupon, Davao Oriental), the Court of Appeals (CA) Decision affirming the RTC, and the Supreme Court review under Rule 45 (G.R. No. 196874). Applicable law referenced in the decision includes the 1987 Constitution (as the decision date is after 1990), Batas Pambansa Blg. 129 (The Judiciary Reorganization Act of 1980) as amended by Republic Act No. 7691, and pertinent provisions of the Rules of Court governing jurisdiction and docket fees.
Factual Background
Respondents claimed that Alejandro Ramiro was the registered owner of the subject lot and that he and his spouse sold it to the Bacarons by a Deed of Sale dated October 20, 1991. The property had been previously mortgaged to DBP; respondents allege they paid DBP P430,150.00 to redeem the property and thereafter possessed it. Petitioners denied material allegations, asserted that the Deed of Sale was in effect an equitable mortgage, contended the RTC lacked jurisdiction, and pleaded laches as a bar to respondents’ claims. Petitioners allegedly took possession of the property in June 1998.
Procedural History Through the Trial Courts
Respondents filed Civil Case No. 1966 (045) in the RTC, amended their complaint and sought, among other reliefs, validation of the Deed of Sale, specific performance (or execution of a conveyance), cancellation of the existing OCT and issuance of a new title, recovery of possession, injunctions, damages and attorneys’ fees. After trial, the RTC (July 13, 2007) declared the Deed of Sale valid, directed execution/registration actions and restoration of possession to respondents, and awarded attorney’s fees. Petitioners appealed to the CA, which on October 19, 2010, affirmed the RTC in toto; a motion for reconsideration was denied by CA resolution (May 3, 2011). Petitioners then filed a petition for review on certiorari under Rule 45 with the Supreme Court.
Issues Presented to the Supreme Court
The petition presented three principal issues: (1) whether the RTC acquired jurisdiction over the subject matter; (2) whether the Deed of Sale dated October 20, 1991 should be treated as an equitable mortgage; and (3) whether respondents’ claims were barred by laches.
CA Rulings on Jurisdiction, Equitable Mortgage and Laches
The CA held that the RTC properly exercised jurisdiction because respondents’ pleadings raised causes of action (declaration of validity of the Deed of Sale, specific performance, recovery of possession, injunctions and damages) that were incapable of pecuniary estimation and thus within the RTC’s exclusive original jurisdiction. The CA also rejected petitioners’ equitable mortgage argument, finding petitioners failed to rebut the RTC’s factual finding that petitioners forcibly dispossessed respondents in June 1998 and that the tax receipts did not show continuous tax payments inconsistent with respondents’ claim of possession. The CA found petitioners’ laches argument unproven.
Supreme Court’s Characterization of the Action (Real Action v. Action Incapable of Pecuniary Estimation)
The Supreme Court examined the amended complaint’s averments and the reliefs sought. Although respondents labeled the action as one for validation of a Deed of Sale and for specific performance, the Court found that the substance of the pleading and the reliefs (cancellation of the existing title, issuance of a new title, recovery of possession and injunctions to protect possession) showed the primary objective was recovery of real property and determination of title. The Court reiterated the settled rule that the nature of the action and the court having original and exclusive jurisdiction are determined by the material allegations of the complaint and the reliefs sought, regardless of the labels used by plaintiffs.
Statutory Framework Governing Jurisdiction and Docket Fees
The Court relied on the jurisdictional divisions under B.P. Blg. 129 as amended by R.A. No. 7691: Section 19 vests the RTC with exclusive original jurisdiction in civil actions incapable of pecuniary estimation and in actions involving title to or possession of real property where the assessed value exceeds statutory thresholds; Section 33 assigns to lower courts exclusive original jurisdiction when the assessed value does not exceed such thresholds. The Court emphasized that when the action primarily involves title to or possession of land, the court with jurisdiction is determined by the assessed value of the property, and that the correct payment of docket fees (b
...continue readingCase Syllabus (G.R. No. 196874)
Case Information and Procedural Posture
- Citation: 846 Phil. 410; 116 OG No. 5, 649 (February 3, 2020); G.R. No. 196874, February 06, 2019; First Division.
- Nature of action: Petition for review on certiorari under Rule 45 assailing the Court of Appeals Decision dated October 19, 2010 and Resolution dated May 3, 2011 in CA-G.R. CV No. 01350-MIN, which affirmed the July 13, 2007 Decision of Branch 32, Regional Trial Court (RTC) of Lupon, Davao Oriental in Civil Case No. 1966 (045).
- Parties:
- Petitioners: The heirs of the late spouses Alejandro Ramiro and Felicisima Llamada — Henry L. Ramiro; Merlyn R. Taguba; Marlon L. Ramiro; Maridel R. Santella; Wilma L. Ramiro; Vilma R. Cielo; Carolyn R. Cordero.
- Respondents: Spouses Eleodoro and Verna Bacaron.
- Panel and author: Decision penned by Justice J. Jardeleza (Acting Chairperson per Special Order No. 2636 dated January 31, 2019). Bersamin, C.J., Gesmundo, and Carandang, JJ., concur. Del Castillo, J., on official leave.
Factual Background
- Registered ownership: The late Alejandro Ramiro was the registered owner of Lot 329, Cad-600, containing about 48,639 square meters, covered by Original Certificate of Title (OCT) No. P-12524; property used primarily as a fishpond with portions planted with coconut trees.
- Alleged sale: Spouses Alejandro Ramiro and Felicisima Llamada allegedly sold the property to spouses Bacaron by a Deed of Sale dated October 20, 1991.
- Possession and redemption: Spouses Bacaron claimed they took possession after the sale and paid the Development Bank of the Philippines (DBP) P430,150.00 to redeem the property because it had earlier been mortgaged by the Ramiro spouses.
- Deaths: Alejandro Ramiro died circa 1996; Felicisima Llamada died circa 1997.
- Dispossession claim: Spouses Bacaron allege that in June 1998 petitioners forcibly dispossessed them of the property.
- Deed of Sale evidence: The original Deed of Sale was lost; respondents introduced secondary evidence to prove its existence and contents.
- Realty taxes and receipts: Petitioners claimed payment of realty taxes, but official receipts presented showed payments for 1991 and 1992, and for 1993 and 1994, were issued on August 17, 1998 and March 12, 1999, respectively.
Reliefs Sought by Respondents in the Amended Complaint
- Preliminary and permanent injunctive reliefs:
- Temporary Restraining Order (TRO) and preliminary mandatory and prohibitory injunctions enjoining defendants from acts inimical to plaintiffs’ claimed ownership and directing return of possession.
- Making said injunctions permanent after hearing.
- Declaratory and specific performance reliefs:
- Declaration of validity and effectivity of the Deed of Sale dated October 20, 1991, and specific performance or, alternatively, an order directing defendants to execute the proper deed or instrument of conveyance transferring the property to plaintiffs.
- Cancellation of OCT No. P-12524 and issuance of a new title in plaintiffs’ names.
- Restoration of peaceful and undisturbed possession to plaintiffs.
- Monetary and incidental reliefs:
- Attorney’s fees (P20,000.00) and P1,200.00 appearance fees per hearing.
- Moral damages of P100,000.00 and exemplary damages to be fixed by the Court.
- Other just and equitable reliefs.
Petitioners’ Pleadings and Affirmative Defenses
- Denial of material allegations in the amended complaint.
- Affirmative defenses raised:
- Lack of RTC jurisdiction, contending that the action involved recovery of possession and should be governed by jurisdictional limits under B.P. Blg. 129 as amended by R.A. No. 7691.
- The instrument called a Deed of Sale should be construed as an equitable mortgage given petitioners’ actual physical possession and payment of taxes.
- Laches barred respondents from instituting the complaint.
RTC (Trial Court) Decision (July 13, 2007)
- Findings of fact:
- The RTC found that spouses Bacaron proved by preponderance of evidence the due execution of the Deed of Sale dated October 20, 1991 despite loss of the original; competent secondary evidence established its existence.
- The stated purchase price of P400,000.00 in the Deed corresponded, more or less, to the P430,150.00 respondents paid to DBP for redemption.
- Petitioners forcibly dispossessed respondents in June 1998.
- Dispositive orders (as rendered by the RTC):
- Declared valid the Deed of Sale dated October 20, 1991.
- Directed defendants to execute a Deed of Extra-Judicial Partition with Confirmation of the Sale in favor of plaintiffs within fifteen (15) days from finality of decision, with execution pursuant to law and rules if defendants fail to comply.
- Directed the Register of Deeds to register the parcel in plaintiffs’ names upon presentation of the said deed.
- Directed defendants and persons acting for them to vacate the property and restore possession to plaintiffs.
- Directed defendants to pay P30,000.00 as reasonable attorney’s fees.
Court of Appeals Disposition (October 19, 2010) and Motion for Reconsideration (May 3, 2011 Resolution)
- CA ruling:
- Affirmed the RTC Decision in toto.
- Upheld RTC jurisdiction over the case, reasoning that the amended complaint alleged causes of action (declaration of validity of sale, specific performance, recovery of possession, damages, attorney’s fees, and injunction) which the CA deemed incapable of pecuniary estimation, thereby permitting joinder under the Rules of Court and falling within RTC jurisdiction.
- Rejected petitioners’ equitable mortgage theory, finding petitioners failed to assail the trial court’s finding that petitioners’ present possession resulted from forcible dispossession in June 1998.
- Disputed petitioners’ claims of timely payment of realty taxes, pointing to officia