Case Summary (G.R. No. 160384)
Key Dates
Complaint filed in RTC: September 3, 1996.
Tax declaration introduced at trial showing assessed value (1991): P5,950.00.
RTC decision: June 3, 1999 (found for petitioners).
Court of Appeals (CA) decision: May 23, 2003 (reversed; dismissed for lack of jurisdiction).
Supreme Court decision under review: petition resolved in favor of CA (petition denied).
Applicable Law and Legal Framework
- Constitution in effect for the decision: 1987 Constitution.
- Statutory controls on jurisdiction cited: Batas Pambansa Blg. 129 (Judicature Act), as amended by Republic Act No. 7691 (which reorganized lower courts and fixed jurisdiction by assessed value).
- Relevant statutory provisions: Section 33(3) of B.P. Blg. 129 (MTCs’ exclusive original jurisdiction where assessed value does not exceed P20,000, exclusive of interest, damages, attorney’s fees, litigation expenses and costs); Section 19(2) and Section 19(8) (RTC exclusive jurisdiction where assessed value or demand exceeds statutory thresholds).
- Administrative Circular No. 09-94 (implementation guidance for R.A. No. 7691): clarifies when damages are excluded or included in determining jurisdictional amount.
- Tax declaration and assessed value: assessed value (taxable value) governs jurisdiction for actions involving title or possession of land; assessed value is synonymous with taxable value and is the fair market value multiplied by the assessment level.
Factual Allegations and Relief Sought
Petitioners alleged co-ownership by inheritance from Concepcion Mazo Salvador and asserted that respondent constructed his dwelling on the land in 1989 without family knowledge or consent and refused to vacate despite demands. Plaintiffs sought an order for defendant to vacate and peacefully turn over the occupied property, plus actual, moral and exemplary damages, transportation expenses, attorney’s fees and other relief.
Motion to Dismiss and Parties’ Positions on Jurisdiction
Respondent moved to dismiss for lack of jurisdiction under Section 33 of B.P. Blg. 129 as amended by R.A. No. 7691, arguing that the complaint omitted the assessed value of the subject land and did not sufficiently describe the parcel, thereby preventing determination of proper forum; respondent suggested the assessed value could not exceed P20,000 and thus the Municipal Trial Court (MTC) had exclusive jurisdiction. Petitioners opposed, arguing the RTC could take judicial notice of market value (P200/sq.m. × 14,797 sq.m. = P3.5M) and that the motion was premature until they presented evidence.
RTC Ruling on Motion to Dismiss and Subsequent Trial
The RTC denied the motion to dismiss, concluding the action was “incapable of pecuniary estimation” and hence cognizable by the RTC under Section 19(1) of B.P. Blg. 129 as amended. Trial proceeded; petitioners introduced Tax Declaration No. 8590-A showing an assessed value of P5,950.00 (1991). The RTC ultimately ruled for petitioners, ordering defendant to vacate and dismissing defendant’s counterclaim.
CA Ruling and Rationale
On appeal the CA reversed and dismissed the complaint for lack of jurisdiction, holding that the action was one for recovery of ownership and possession of real property and that, absent any allegation of assessed value in the complaint, exclusive jurisdiction rested with the MTC under Section 33(3) of R.A. No. 7691. The CA relied on the tax declaration presented in evidence (assessed value P5,950.00) and reasoned that the assessed value in the tax rolls determines jurisdiction; a plaintiff’s loose reference to market value (P3.5M) was irrelevant where a tax declaration existed.
Issue Presented to the Supreme Court
Whether the RTC had original jurisdiction over the petitioners’ action, or whether jurisdiction belonged exclusively to the MTC, given the statutory scheme in R.A. No. 7691 and the factual allegations and proofs before the courts.
Nature of the Action — Accion Reinvindicatoria vs. Accion Publiciana
The Court analyzed the pleadings and relief sought to determine the real nature of the action. An accion reinvindicatoria is an action to recover property as owner (seeking ownership and possession). An accion publiciana (ejectment-type) is for recovery of possession based on a right to possess (often filed after one year from loss of possession or unlawful withholding). The Court found the complaint sought only restoration of possession and did not properly assert a claim of ownership; thus, the action was an accion publiciana (recovery of possession) and not an accion reinvindicatoria.
Jurisdictional Rule — Assessed Value Controls
Under the statutory scheme, jurisdiction for actions involving title or possession is determined by the assessed value (taxable value) of the property as appearing in tax rolls/tax declarations, not by market value. Section 33(3) directs exclusive MTC jurisdiction where assessed value does not exceed P20,000 (provincial cases). Section 19(2) assigns RTC jurisdiction where assessed value exceeds P20,000. The Court emphasized that assessed value, not market value, is determinative.
Judicial Notice and Proof of Assessed Value
The Court held that courts cannot take judicial notice of assessed or market values of lands; jurisdiction must appear from the complaint (i.e., pleading must allege assessed value) or be established by competent evidence such as a tax declaration. The petitioners did not allege assessed value in their complaint; they later introduced a 1991 tax declaration showing assessed value of P5,950.00, but they did not present an assessed value as of the time of filing. Even assuming assessed value had not changed, that figure placed the case within MTC jurisdiction.
Role of Tax Declaration and Presumption of Regularity
The Court recognized the tax declaration as the proper source of assessed value and afforded it the presumption of regularity as an official document issued by the appropriate agency. Where a tax declaration exists showing assessed value below the statutory RTC threshold, the MTC has exclusive jurisdiction.
Damages Argument and Exclusion Rule
Petitioners argued that their claim included damages exceeding P20,000, which would invoke RTC jurisdiction. The Court rejected this, citing the explicit statutory exclusion: interest, damages of whatever kind, attorney’s fees, liti
Case Syllabus (G.R. No. 160384)
Case Caption, Court and Decision Sought
- Petition for review on certiorari under Rule 45 of the Revised Rules of Court.
- Review sought of the Decision of the Court of Appeals in CA-G.R. CV No. 63737 and its Resolution denying motion for reconsideration.
- Supreme Court decision rendered April 29, 2005, reported at 497 Phil. 327, Second Division; opinion penned by Justice Callejo, Sr.
Parties and Standing
- Petitioners: Cesar T. Hilario, for himself and as attorney-in-fact of Ibarra, Nestor, Lina and Prescilla Hilario — co-heirs asserting co-ownership by inheritance from Concepcion Mazo Salvador.
- Private respondent/defendant in RTC: Allan T. Salvador — occupant of the property and builder of a dwelling unit thereon.
- Respondents-intervenors: Heirs of Salustiano Salvador, specifically Regidor M. Salvador and Virginia Salvador-Lim (Virginia later dropped as intervenor on her own motion).
- Petitioners asserted their hereditary share adjudication as heirs of Brigido M. Hilario, Jr., known to their father as co-heirs.
Property and Core Dispute Allegations
- Subject property designated as Cad. Lot No. 3113-part, located at Sawang, Romblon, Romblon.
- Petitioners alleged defendant constructed a mixed-materials dwelling on the property in or about 1989 without their or their predecessors-in-interest’s knowledge, and refused to vacate despite demands.
- Petitioners sought peaceful recovery of the occupied property and alleged suffering of shame, humiliation, wounded feelings, anxiety, sleepless nights, and legal expenses due to defendant’s refusal to vacate.
- Petitioners brought the matter to the Lupon of Barangay Sawang; a "CERTIFICATE TO FILE ACTION" (Annex B) evidencing attempt at local amicable settlement was attached to the complaint.
Reliefs Demanded in the Complaint
- Primary relief: order for defendant to vacate and peacefully turn over the occupied property to plaintiffs.
- Monetary and ancillary reliefs prayed for included:
- Actual expenses: transportation in connection with settlement and attendance at hearings (enumerated amounts).
- Attorney’s fees: P20,000.00 and P500.00 for every court appearance.
- Moral and exemplary damages to be determined by the court.
- Other just and equitable reliefs.
Responsive Pleadings and Motion to Dismiss
- Defendant filed a motion to dismiss for lack of jurisdiction under Section 33 of B.P. Blg. 129 as amended by Section 3(3) of R.A. No. 7691, arguing:
- Complaint failed to state the assessed value of the land in dispute.
- Complaint insufficiently identified/described the parcel for jurisdictional determination.
- From the complaint, it could be surmised assessed value did not exceed P20,000.00, hence action belonged in the Municipal Trial Court (MTC), not the RTC.
- Petitioners opposed the motion, arguing:
- RTC could take judicial notice of market value (alleged P200.00 per sq. m. × approx. 14,797 sq. m. = P3,500,000.00) and thus had jurisdiction.
- Motion to dismiss was premature; proper time to raise jurisdictional issue was after petitioners introduced evidence showing land’s value.
Trial Court Action on Jurisdictional Motion
- On November 7, 1996, RTC Branch 71 of Romblon denied defendant’s motion to dismiss, holding the action was incapable of pecuniary estimation and therefore cognizable by the RTC under Section 19(1) of B.P. Blg. 129, as amended.
Answer, Counterclaim and Intervention
- Defendant filed answer with counterclaim, alleging the property was conjugal property of his grandparents, spouses Salustiano Salvador and Concepcion Mazo-Salvador, and maintained petitioners had no cause of action.
- Regidor and Virginia Salvador filed an Answer-in-Intervention on April 8, 1997; Virginia was later dropped as intervenor on her own motion.
Evidence at Trial
- Petitioners offered Tax Declaration No. 8590-A in evidence, showing an assessed value of the property in 1991 of P5,950.00.
Trial Court Judgment
- On June 3, 1999, the RTC rendered judgment in favor of the petitioners with dispositive ordering:
- Defendant to vacate and peacefully turn over the occupied property to plaintiffs.
- Defendant’s counterclaim dismissed.
Appeal and Court of Appeals Ruling
- Defendant and intervenor Regidor Salvador appealed to the Court of Appeals.
- On May 23, 2003, the CA reversed the RTC decision and dismissed the complaint for want of jurisdiction, ordering dismissal "without prejudice to its refiling in the proper court."
- CA characterized the petitioners’ action as one for recovery of ownership and possession of real property and held that, absent an allegation