G.R. No. 155179 - Quinagoran vs. Court of Appeals

Case Summary (G.R. No. 155179)

Factual Background

The respondents alleged that they are the co-owners and heirs of the late Juan dela Cruz of Lot No. 1807, Pls-149, containing approximately 13,100 square meters and covered by Original Certificate of Title No. P-1670. Sometime in the mid-1960s or mid-1970s, a house was erected on the north-west portion of that lot occupying about 400 square meters. Petitioner began occupying that house by the tolerance of respondents. In 1993 respondents demanded removal of the house to construct a commercial building; petitioner refused and asserted ownership over the portion where the house stood. Respondents prayed for reconveyance and surrender of the disputed 400 square meters, monthly compensation of P5,000.00 until vacation, attorney’s fees of P20,000.00, costs, and other reliefs.

Trial Court Proceedings

Petitioner moved to dismiss, contending that under R.A. No. 7691 the Municipal Trial Court (MTC) or its successors had exclusive original jurisdiction over actions involving title or possession of real property where the assessed value did not exceed P20,000.00 outside Metro Manila. Petitioner argued that the assessed value of the adjacent 346 square meter lot indicated a low assessed value for the disputed portion. The RTC denied the motion to dismiss by Order of November 11, 1999, reasoning that the complaint was in the nature of an accion publiciana and that jurisdiction over such plenary actions rested with the RTC regardless of the assessed value. The RTC likewise denied petitioner’s motion for reconsideration.

Proceedings in the Court of Appeals

Petitioner sought relief from the CA via a petition for certiorari and prohibition challenging the RTC’s orders. The CA, in a Decision dated May 27, 2002, dismissed the petition and affirmed the RTC. The CA found that the complaint adequately alleged facts showing an accion publiciana—that petitioner’s occupancy was by tolerance, that respondents demanded removal in 1993, that petitioner refused and claimed ownership, and that a survey established occupation of 400 square meters. The CA held that where a complaint fails to aver forcible entry or unlawful detainer methods, the proper remedy is an accion publiciana or accion reinvindicatoria, which falls within the exclusive original jurisdiction of the RTC, irrespective of assessed value. The CA denied petitioner’s motion for reconsideration on August 28, 2002.

Issues Presented to the Supreme Court

The petition to the Supreme Court raised two principal issues: whether, in light of R.A. No. 7691, the expanded jurisdictional limits for MTCs and their successors deprived the RTC of original jurisdiction over an action to recover possession when the assessed value of the property did not exceed P20,000.00; and whether a complaint must allege the assessed value of the property to establish which court has original jurisdiction.

Petitioner’s Contentions

Petitioner asserted that R.A. No. 7691 conferred exclusive original jurisdiction on the MTC, MeTC, and MTCC for civil actions involving title or possession where the assessed value did not exceed P20,000.00 outside Metro Manila. He maintained that the complaint before the RTC did not allege that the assessed value of the disputed land exceeded P20,000.00, and that no tax declaration was attached to establish assessed value. Petitioner submitted a tax declaration indicating an assessed value of P551.00 for the parcel, and thus prayed that the CA decision and resolution be annulled and that the RTC complaint be dismissed for lack of jurisdiction.

Respondents’ Contentions

Respondents countered that the CA’s decision was correct and that the complaint did not state that the assessed value was below P20,000.00. They argued that petitioner’s reliance on the assessed value of an adjacent property was unsupported at the trial level. Respondents further contended that the tax declaration petitioner later presented should not be credited because it reflected P56,100.00 for the entire property, not the low figure asserted by petitioner.

Supreme Court’s Ruling

The Supreme Court granted the petition. The Court reversed and set aside the CA Decision and Resolution, declared null and void the RTC Orders of November 11, 1999 and May 11, 2000 and all proceedings therein, and dismissed the complaint in Civil Case No. 240-T without prejudice. No costs were imposed.

Legal Basis and Reasoning

The Court began from the premise that jurisdiction depends upon the material allegations of the complaint and the law in force when the action is filed. The Court held that R.A. No. 7691, which took effect on April 15, 1994, amended the jurisdictional scheme by providing in Section 19 and Section 33 that regional trial courts exercise exclusive original jurisdiction in civil actions involving title to or possession of real property where the assessed value exceeds P20,000.00 outside Metro Manila, while metropolitan and municipal trial courts exercise exclusive original jurisdiction where the assessed value does not exceed P20,000.00. The Court explained that prior decisions treating all accion publiciana as exclusively within the RTC regardless of value no longer controlled after R.A. No. 7691. The Court then addressed whether the complaint must allege the assessed value of the property. Citing prior decisions, the Court held that a complaint must allege the assessed value of the real property or interest therein to determine which court has jurisdiction. The Court found that the respondents’ complaint contained no allegation of the assessed value. Consequently, the Court conclu

Case Syllabus (G.R. No. 155179)

Parties and Posture

Victorino Quinagoran filed a Petition for Review on Certiorari under Rule 45, Rules of Court seeking annulment of the Court of Appeals' decision and resolution.
Court of Appeals and the Heirs of Juan de la Cruz are the respondents in the petition.
The action below was docketed as Civil Case No. 240-T before the Regional Trial Court, Branch XI of Tuao, Cagayan.
The petition assailed the CA Decision dated May 27, 2002 and its Resolution dated August 28, 2002 which affirmed the RTC's denial of a motion to dismiss.

Factual Allegations

The Heirs of Juan dela Cruz alleged that they inherited Lot No. 1807 containing 13,100 square meters and that it is covered by Original Certificate of Title No. P-1670.
The respondents alleged that Petitioner began occupying a house on the north-west portion of the lot in the mid-70s by the respondents' tolerance and that the house occupies about 400 square meters.
The respondents alleged that in 1993 they demanded removal of the house to construct a commercial building and that Petitioner refused and claimed ownership of the portion where the house stands.
The respondents prayed for reconveyance and surrender of the contested 400 square meters, P5,000.00 monthly until vacation, attorney's fees of P20,000.00, costs, and other equitable reliefs.

Procedural History

Petitioner filed a Motion to Dismiss in the RTC asserting lack of jurisdiction in light of R.A. No. 7691 and alleging that the assessed value of the disputed lot did not exceed P20,000.00.
The RTC denied the Motion to Dismiss in an Order dated November 11, 1999 and denied the Motion for Reconsideration thereafter.
Petitioner filed a petition for certiorari and prohibition with the Court of Appeals, which dismissed the petition and affirmed the RTC in a Decision dated May 27, 2002 and denied reconsideration on August 28, 2002.
Petitioner elevated the matter to the Supreme Court by way of a Rule 45 petition, which resulted in the present decision.

Issues Presented

Whether the RTC had jurisdiction to entertain an action for recovery of possession when the complaint did not allege the assessed value of the property.
Whether a complaint for recovery of possession must allege the assessed value of the property to determine whether jurisdiction lies with the RTC or with the municipal trial courts under R.A. No. 7691.

Contentions

Petitioner contended that R.A. No. 7691 expanded the exclusive original jurisdiction of the municipal trial courts to civil actions involving title or possession where the assessed value does not exceed P20,000.00 outside Metro Manila, and that the complaint failed to allege assessed