Case Summary (G.R. No. 204970)
Petitioner
Spouses Claudio and Carmencita Trayvilla.
Respondent
Bernardo Sejas and Juvy Paglinawan (represented by Jessie Paglinawan).
Key Dates
• 1982 – Alleged sale of the disputed land to petitioners.
• 2005 – Filing of original Complaint for specific performance and damages.
• Sept. 3, 2007 & Feb. 21, 2008 – RTC orders denying respondents’ motion to dismiss.
• Nov. 29, 2011 – Court of Appeals Decision nullifying RTC orders and dismissing for lack of jurisdiction.
• Nov. 19, 2012 – CA Resolution denying motion for reconsideration.
• Feb. 1, 2016 – Supreme Court decision affirming the CA.
Applicable Law
• 1987 Philippine Constitution
• Rules of Court: Rule 4 (real actions), Rule 141 (court fees) as amended by A.M. No. 04-2-04-SC and SC Circular No. 35-2004
• Batas Pambansa Blg. 129 (RTC jurisdictional thresholds)
Factual Antecedents
Petitioners bought the land in 1982 and took exclusive possession. In 2005 they sued Sejas for specific performance and damages. An amended complaint added Paglinawan as defendant, sought cancellation of her title, reconveyance, and moral damages. Petitioners failed to allege the property’s fair market value or pay additional docket fees.
Trial Court Proceedings
Respondents moved to dismiss for lack of jurisdiction (improper fee payment) and prescription. The RTC denied dismissal, treating the suit as one for specific performance—an action not subject to value-based filing fees.
Court of Appeals Ruling
The CA granted respondents’ certiorari petition. It held that the amended complaint constituted a real action affecting title, requiring the fair market value declaration under Section 7(1), Rule 141 for proper fee assessment. Its omission deprived the RTC of jurisdiction, voiding its orders and mandating dismissal.
Issues
- Whether the CA properly dismissed the case for failing to allege property value and pay correct docket fees.
- Whether the amended complaint ousted the RTC of jurisdiction previously acquired by the original complaint.
Petitioners’ Arguments
Petitioners argued that reconveyance was incidental to specific performance, that jurisdiction attached with the original complaint and persisted, and that any fee deficiency could be cured by payment or disregarding the amendment. They invoked liberal procedural application.
Respondents’ Arguments
Respondents maintained the amended complaint transformed the suit into a real action requiring value-based fees; non-payment warranted dismissal.
Supreme Court Ruling
The
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Facts
- In 1982, respondent Bernardo Sejas allegedly sold a 434-sq.-m. parcel of land in Tukuran, Zamboanga del Sur (TCT No. T-8,337) to petitioners by a private handwritten document.
- Petitioners took possession of the land, built a house thereon, and continuously resided in it.
- Sejas later reasserted ownership, prompting petitioners to annotate an adverse claim on the title.
Original and Amended Complaints
- 2005 Complaint for specific performance and damages: petitioners prayed for an order compelling Sejas to execute a final deed of sale, transfer ownership, and award P30,000 attorney’s fees plus P1,500 per counsel appearance.
- Amended Complaint added respondent Juvy Paglinawan as a defendant, alleging Sejas sold the same land to her, cancelled TCT T-8,337, and secured TCT T-46,627 in her name.
- New prayers included cancellation of Paglinawan’s title, reconveyance to petitioners, P50,000 moral damages, plus the original damages and attorney’s fees.
- Petitioners did not pay additional docket fees for the amended causes of action and new reliefs.
RTC Proceedings
- Respondents moved to dismiss for lack of subject-matter jurisdiction (arguing the case was a real action requiring valuation and proper fees) and prescription (10-year prescriptive period had lapsed).
- RTC Branch 18 denied the dismissal motion in orders dated September 3, 2007, and February 21, 2008, holding that the suit was for specific performance (incapable of pecuniary estimation) and thus no additional fees were due.
Court of Appeals Ruling
- Respondents filed a Petition for Certiorari (CA-G.R. SP No. 02315).
- On November 29, 2011, the CA granted certiorari, finding the amended complaint a real action because it sought reconveyance and cancellation of title, thus affecting ownership.
- The CA held that Rule 141, Sec. 7(1) requires the allegation of the fair market value in