Case Summary (G.R. No. 217755)
Trial Court Proceedings
Petitioner Elmer filed a complaint in the RTC of Bangued for:
- Declaration of nullity of the Affidavit of Adjudication
- Cancellation of Tax Declaration No. 5289 and OCT No. P-14452
- Reconveyance of the property to Dominga’s heirs
- Damages and preliminary injunction
Respondents Santiago and Charlie moved to dismiss, asserting that:
- Under Section 19 of BP 129, an assessed value below ₱20,000 places jurisdiction in the Municipal Trial Court, not the RTC.
- Section 48 of PD 1529 prohibits collateral attack on Torrens titles, rendering the complaint a collateral attack.
The RTC denied the motion on September 3, 2013, finding the cause incapable of pecuniary estimation and constituting a direct attack on the title. A motion for reconsideration was likewise denied on November 8, 2013. Respondents then filed a Rule 65 petition in the Court of Appeals.
Court of Appeals Ruling
The CA granted the Rule 65 petition, holding:
- The principal issue is ownership and possession of the real property, not merely invalidation of documents.
- The assessed value of ₱3,010 places jurisdiction exclusively in the Municipal or Metropolitan Trial Courts under BP 129, Section 19.
- The RTC therefore lacked jurisdiction and should have granted the motion to dismiss.
Issue on Appeal
Whether the RTC had jurisdiction over a complaint that ultimately involves title to, possession of, or interest in real property with an assessed value below ₱20,000, or whether the action is an equitable claim incapable of pecuniary estimation under Article VIII, Section 5(5) of the 1987 Constitution and BP 129.
Supreme Court Ruling
The Supreme Court affirmed the CA Decision and Resolution, holding that:
- Jurisdiction over subject matter is conferred by law and cannot be waived. Under BP 129, as amended by RA 7691, RTCs do not have original jurisdiction over civil actions involving title to or possession of real property with assessed value not exceeding ₱20,000.
- An action “involving title to real property” is determined by the plaintiff’s allegations and principal relief sought. Here, petitioner Elmer primarily sought to establish and confirm his ownership and possession rights, with cancellation of the Torrens documents following as a necessary consequence.
- Even if cast as an annulment of documents, the underlying claim
Case Syllabus (G.R. No. 217755)
Facts and Antecedent Proceedings
- Dominga Taeza was the second legal wife of Jose Montero; her heirs included Alfredo, Pacita, Marcela, Ernesto, and an illegitimate son Federico Taeza. Elmer Montero is a surviving heir of Alfredo Montero.
- Dominga died intestate in 1975, owning a parcel of land in Pilar, Abra. Free Patent No. 27941 (issued January 11, 1939) and successive tax declarations evidenced her possession.
- Upon her death, possession of the land passed by operation of law to her successors‐in‐interest.
- In 1989, respondent Santiago Montero, Jr. executed an Affidavit of Adjudication misrepresenting himself as Dominga’s sole heir. This led to the cancellation of Tax Declaration No. 417 and issuance of Tax Declaration No. 5289, and Original Certificate of Title (OCT) No. P-14452 in his name.
- Around 2002, respondents Santiago and Charlie Montero threatened Ernesto Montero and constructed houses on the residential portion of the land, refusing to reconvey to Dominga’s heirs.
Complaint and Reliefs Sought
- Petitioner Elmer Montero filed before RTC Branch 2 of Bangued a Complaint for:
- Declaration of nullity of the Affidavit of Adjudication;
- Cancellation of Tax Declaration No. 5289 and OCT No. P-14452;
- Reconveyance of the subject property to Dominga’s heirs;
- Damages; and
- Preliminary injunction.
- The action was docketed as Civil Case No. 3107.
Motion to Dismiss and RTC Ruling
- Respondents moved to dismiss on two grounds:
- RTC lacked jurisdiction because the assessed value of the property (₱3,010) did not exceed ₱20,000, vesting jurisdiction in Municipal Trial Courts under Section 19 of BP 129.
- The action constituted a collateral attack on an