Case Summary (G.R. No. L-27388)
Antecedents
The conflict originated from a complaint filed by the petitioners against the private respondent, Alvin Cruz, concerning the recovery of real property, specifically a parcel of land located at Juan Luna Street, Poblacion, Davao City. The land in question was registered under Transfer Certificate of Title No. T-296879, with the petitioners claiming ownership in fee simple. The petitioners reported a lost original owner's duplicate of the title, leading to police involvement and the subsequent filing of an Affidavit of Loss, which outlined discovered fraudulent entries on the title. They alleged that their signatures were forged on an Affidavit of Recovery and a Special Power of Attorney, both of which were used to facilitate the unauthorized sale of the property to Cruz for P1,488,000.00.
Respondent's Defense
In response, the private respondent denied petitioners' claims and asserted that he was a good faith purchaser for value. He argued that he received offers for the property from third parties and claimed unbothered possession since the purchase. The private respondent also denied any wrongdoing or knowledge regarding the alleged forgeries related to the Affidavit of Recovery and Special Power of Attorney.
RTC Ruling
The Regional Trial Court (RTC) denied the private respondent's motion to dismiss on jurisdictional grounds, asserting that the assessed value of the property did not confer jurisdiction on the Municipal Trial Court (MTC). The RTC's subsequent rulings reinforced its jurisdiction over the case.
CA Decision
Upon appeal, the Court of Appeals (CA) ruled that the determination of jurisdiction was contingent on the assessed value of the property as stated in the complaint, which was P19,840.00. Consequently, the CA declared that the MTC had exclusive jurisdiction over the proceedings. The petitioner’s motion for reconsideration was subsequently denied through a resolution issued by the CA.
Issues Raised
The petitioners raised several issues including claims of grave abuse of discretion by the CA regarding the classification of the action as one incapable of pecuniary estimation and the resulting jurisdictional determinations. They contended that the RTC should retain jurisdiction over this matter.
Procedural Flaws and Legal Principles
The Supreme Court determined that the petition for certiorari was improperly filed as it should have been a verified petition for review under Rule 45, given that there was an adequate remedy through an appeal available to the petitioners. The reliance on certiorari as a remedy was characterized as a fatal procedural error, thus resulting in the dismissal of their petition for lack of merit.
Substantive Merits
On substantive review, the Supreme Court highlighted that actions for recon
...continue readingCase Syllabus (G.R. No. L-27388)
Background of the Case
- The case involves a Petition for Certiorari filed by Spouses Jimmy M. Liu and Emile L. Liu (petitioners) against the Court of Appeals (CA), Regional Trial Court (RTC) Branch 17, and Alvin Cruz (private respondent).
- The petition sought to annul the CA Decision dated July 31, 2017, and the Resolution dated January 31, 2018.
- The underlying matter originated from a complaint for recovery of real property (accion reivindicatoria), reconveyance, and declaring certain documents null and void, filed by the petitioners against the private respondent.
Antecedents of the Case
- The petitioners claimed ownership of a parcel of land covered by Transfer Certificate of Title (TCT) No. T-296879, located in Davao City, with an assessed value of ₱19,840.00 and a market value of ₱99,200.00.
- They reported the loss of their original owner's duplicate copy of TCT No. T-296879, which led to a police investigation documented in Police Blotter Entry No. 457 dated March 22, 2005.
- An Affidavit of Loss was subsequently executed and annotated on the original title, revealing fraudulent annotations, including a sham Affidavit of Recovery and a spurious Special Power of Attorney.
- The private respondent, Alvin Cruz, allegedly acquired the property through a deed of sale that did not bear the petitioners' signatures and was notarized without their consent.
Allegations and Responses
- The petitioners asserted that the documents concerning their property were forgeries and that they never received