Case Summary (G.R. No. 202448)
Properties and Initial Possession Dispute
The respondents, as registered owners of two titled parcels, discovered in the 1995–1996 crop year that petitioner had, without consent or payment of rent, entered and cultivated sugar cane on the properties. Verbal demands for vacatur were made but ignored by petitioner.
Barangay Proceedings and Filing of Complaint
A confrontation before the Barangay Captain and Lupon Tagapamayapa of Cansilayan, Murcia, failed to yield a settlement. A Certificate to File Action issued on September 29, 1997, led respondents to file a complaint for recovery of possession, damages, and injunction on March 9, 1998, in the RTC of Bacolod City, Branch 42.
Petitioner's Waivers and Motion to Dismiss
Petitioner alleged that five respondents had executed waivers of their undivided shares in favor of Jaime, who in turn waived his rights in petitioner’s favor, thereby extinguishing respondents’ claims. He moved to dismiss for lack of RTC jurisdiction, characterizing the action as ejectment proper to the Municipal Trial Court given it was filed within one year of the barangay confrontation.
RTC Decision and Appeal to CA
On January 20, 2009, the RTC denied the motion to dismiss, presuming the properties’ value exceeded ₱20,000, thus vesting RTC jurisdiction, and ordered petitioner to return possession and pay attorney’s fees. Both sides appealed to the Court of Appeals (CA).
CA Decision and Issues on Review
On May 28, 2012, the CA affirmed the RTC decision. It held that petitioner failed to prove consideration for the waiver from Jaime, and respondents failed to establish entitlement to damages. The CA also noted a stipulation on RTC jurisdiction and presumed the assessed value exceeded ₱20,000.
Issues on Certiorari
- Whether the RTC had jurisdiction over the complaint.
- Whether petitioner should return possession.
- Whether petitioner is liable for damages.
Petitioner’s Jurisdiction Argument
Petitioner insisted the complaint was for ejectment—filed within one year of unlawful deprivation—and thus exclusively within Municipal Trial Court jurisdiction. He further argued that, even as an accion publiciana, the absence of an alleged assessed value in the complaint deprived the RTC of jurisdiction.
Respondents’ Loan and Waiver Defense
Respondents countered that the waivers to Jaime and subsequently to petitioner were conditional upon payment of a ₱6.7 million bank loan and bank consent. No payment or consent occurred, rendering the waivers void and preserving respondents’ possessory rights.
Supreme Court’s Jurisdiction Analysis
Under Rule 70 and RA 7691, actions for forcible entry or unlawful detainer (ejectment) must allege specific jurisdictional facts and be filed in lower courts within one year. Plenary actions (accion publiciana) require that the assessed value of the property be alleged to determine MTC/RTC jurisdiction.
Classification of Possession Actions
The Court identified three remedies for recovery of real property: ejectment (forcible entry or unlawful detainer) within one year; accion publiciana for possession rights after one year; and accion reinvindicatoria to recover ownership. Jurisdiction depends on action type and assessed value.
Ejectment vs. Accion Publiciana
Respondents’ complaint lacked facts of forcible entry or unlawful detainer necessary for ejec
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Facts
- Respondents Emma, Jesusa, Johnny, Johanna, Jose, Jessica, and Jaime Antonio de la Pena own two parcels (Lot Nos. 138-D and 138-S) in Murcia, Negros Occidental, with a combined area of 44 hectares, covered by TCT Nos. T-103187 and T-103189.
- In 1994, petitioner Joseph O. Regalado entered the subject properties without respondents’ knowledge or consent, took possession, and planted sugar cane without paying rent.
- During the 1995–1996 crop year, respondents discovered the illegal entry and orally demanded that petitioner vacate; he refused.
- A conference before the Barangay Cansilayan’s Lupon Tagapamayapa failed to resolve the dispute; a Certificate to File Action was issued on September 29, 1997.
RTC Proceedings
- On March 9, 1998, respondents filed a Complaint for Recovery of Possession and Damages with Injunction (Civil Case No. 98-10187, RTC Bacolod City, Branch 42).
- Petitioner’s Answer alleged that respondents had executed waivers of their undivided shares in favor of Jaime, who in turn waived his rights to petitioner, thus nullifying respondents’ claim.
- Petitioner moved to dismiss for lack of jurisdiction, contending the action was ejectment—under one year from barangay referral—and belonged to the Municipal Trial Court (MTC).
- In their Reply and later Opposition, respondents argued the waivers were void for lack of bank consent and conditional on payment of a P6.7 million loan; they also asserted RTC jurisdiction based on the timing of their demand.
- On July 31, 2000, the RTC denied the Motion to Dismiss, presuming the property’s value exceeded P20,000 and thus falling under its exclusive jurisdiction.
- On January 20, 2009, the RTC order