Heirs of Danilo Arrienda vs. Kalaw Heirs of Danilo Arrienda vs.

Kalaw, 788 SCRA 542

Danilo Arrienda (Arrienda) filed against herein respondent and three other persons a Complaint3 for unlawful
detainer with the Municipal Trial Court (MTC) of Calauan, Laguna.

On November 20, 2002, the MTC rendered its Decision6 dismissing the complaint on the ground of lack of
jurisdiction

On appeal by Arrienda, the RTC agreed with the MTC that jurisdiction lies with the RTC

the RTC held that since it was established that Arrienda is the owner of the subject lot, he is, under the law, entitled
to all the attributes of ownership of the property, including possession thereof.

The CA held that the RTC did not acquire jurisdiction over the case for Arrienda’s failure to allege the assessed value
of the subject property and, as a consequence, the assailed RTC Decision is null and void.

Issue: whether or not the RTC has jurisdiction over Arrienda’s appeal of the MTC Decision.

Held:

The Court does not agree with the ruling of the CA that the RTC lacks jurisdiction over the case on the ground that
Arrienda failed to allege the assessed value of the subject land in his Complaint.

It is true that under the prevailing law, as discussed above, in actions involving title to or possession of real property
or any interest therein, there is a need to allege the assessed value of the real property subject of the action, or the
interest therein, for purposes of determining which court (MeTC/MTC/ MCTC or RTC) has jurisdiction over the
action.

However, it must be clarified that this requirement applies only if these courts are in the exercise of their original
jurisdiction.

Clearly then, in the instant case, contrary to the ruling of the CA, the assessed value of the disputed lot is immaterial
for purposes of the RTC’s appellate jurisdiction
 Bankgo Sentral ng Pilipinas vs. Legaspi 785 SCRA 466

Petitioner BSP filed a Complaint for annulment of title, revocation of certificate and damages (with application for
TRO/writ of preliminary injunction) against Secretary Jose L. Atienza, et.al. before the RTC of Malolos, Bulacan.

Respondent Legaspi filed a motion for reconsideration, adding as its argument that the RTC failed to acquire
jurisdiction over the action because the complaint, a real action, failed to allege the assessed value of the subject
property.

Petitioner BSP further stated that a tax declaration showing the assessed value of P28,538,900.00 and latest zonal
value of P145,162,080.00 was attached to the complaint.

The RTC, in its Order dated April 3, 2009, denied respondent Legaspi’s motion for reconsideration.

Hence, respondent Legaspi elevated the case to the CA via a petition for certiorari under Rule 65 of the Rules of
Court. The CA granted respondent Legaspi’s petition.

Issue: The Regional Trial Court of Malolos City has exclusive original jurisdiction over the subject matter of Civil Case
No. 209-M-2008.

Held: Under Batas Pambansa Bilang 129, as amended by Republic Act No. 7691, the RTC has exclusive original
jurisdiction over civil actions which involve title to possession of real property, or any interest therein, where the
assessed value of the property involved exceeds Twenty Thousand Pesos (P20,000.00).

The noninclusion on the face of the complaint of the amount of the property, however, is not fatal because attached
in the complaint is a tax declaration (Annex “N” in the complaint) of the property in question showing that it has an
assessed value of P215,320.00.

It must be emphasized that annexes to a complaint are deemed part of, and should be considered together with the
complaint.

Hence, being an annex to BSP’s complaint, the tax declaration showing the assessed value of the property is deemed
a part of the complaint and should be considered together with it in determining that the RTC has exclusive original
jurisdiction.
 Corpuz v. Agustin, G.R. No. 183822, January 18, 2012, 663 SCRA 350

The Spouses Dumlao filed a complaint for recovery of possession before the Regional Trial Court (RTC) against the
defendants Hernan, Susan, and the Spouses Erorita.

A review of the complaint shows that: (a) the owners, Spouses Dumlao, agreed to allow the petitioners to continue
operating the school on the disputed property; (b) in a demand letter dated February 12, 2004, the Spouses Dumlao
told the petitioners to pay and/or vacate the property; (c) the respondents refused to vacate the property; and (d)
the Spouses Dumlao filed the complaint (March 4, 2004) within a year from the last demand to vacate

the RTC decided in the Spouses Dumlao’s favor. It ordered the defendants (1) to immediately vacate the property
and turn it over to the Spouses Dumlao, and (2) to pay accumulated rentals, damages, and attorney’s fees.

The defendants Erorita appealed to the CA arguing that the complaint patently shows a case for unlawful detainer.
Thus, the RTC had no jurisdiction over the subject matter of the case.

On appeal, the CA affirmed the RTC’s decision.  

Because the tax declaration showed that the assessed value of the property and its improvements exceeded
P20,000.00, the CA concluded that the RTC had jurisdiction.  

Issue: Whether the RTC had jurisdiction

Held: yes. The allegations in the complaint determine the nature of an action and jurisdiction over the case.
Jurisdiction does not depend on the complaint’s caption. Nor is jurisdiction changed by the defenses in the answer;
otherwise, the defendant may easily delay a case by raising other issues, then, claim lack of jurisdiction.

Thus, although the complaint bears the caption “recovery of possession,” its allegations contain the jurisdictional
facts for an unlawful detainer case. Under RA 7691, an action for unlawful detainer is within the MTC’s exclusive
jurisdiction regardless of the property’s assessed value.
 Tumpag v. Tumpag 737 SCRA 62

On March 13, 1995, Esperanza Tumpag (petitioner) filed a complaint for recovery of possession with damages
against Samuel Tumpag (respondent) before the RTC, Branch 61, Kabankalan City, Negros Occidental.

the respondent moved to dismiss the complaint on the following grounds: failure to state a cause of action; that the
action was barred by prior judgment; and lack of jurisdiction.

The RTC, in an order dated January 16, 1996, denied the respondent’s motion to dismiss and proceeded with pretrial
and trial

In his appeal to the CA, among the grounds the respondent raised was the issue of the RTC’s lack of jurisdiction over
the case.

In its assailed decision, the CA agreed with the respondent and nullified the RTC’s June 3, 2002 decision and all
proceedings before the trial court.

It held that the petitioner’s failure to allege in her complaint the assessed value of the disputed property warranted
the complaint’s dismissal, although without prejudice, because the court’s jurisdiction over the case should be
“determined by the material allegations of the complaint”.

she argues that the dismissal of her complaint was not warranted considering that she had a meritorious case as
attached to her complaint was a copy of a Declaration of Real Property indicating that the assessed value of the
disputed property is P20,790.00.

issue: whether or not the CA is correct in nullifying the RTC judgment

held: It is well-settled that jurisdiction over a subject matter is conferred by law, not by the parties’ action or
conduct, and is, likewise, determined from the allegations in the complaint. Under Batas Pambansa Blg. 129, as
amended by Republic Act No. 7691, the jurisdiction of Regional Trial Courts over civil actions involving title to, or
possession of, real property, or any interest therein, is limited to cases where the assessed value of the property
involved exceeds Twenty thousand pesos (P20,000.00) or, for civil actions in Metro Manila, where such value
exceeds Fifty thousand pesos (P50,000.00), except actions for forcible entry into and unlawful detainer of lands or
buildings.

Here, the petitioner filed a complaint for recovery of possession of real property before the RTC but failed to allege
in her complaint the property’s assessed value. Attached, however, to the petitioner’s complaint was a copy of a
Declaration of Real Property showing that the subject property has a market value of P51,965.00 and assessed value
of P20,790.00.

we held that the factual allegations in a complaint should be considered in tandem with the statements and
inscriptions on the documents attached to it as annexes or integral parts.
 Quinagoran v. Court of Appeals, 531 SCRA 104, 113.

Elenita Dinglasan (Elenita) was the registered owner of a parcel of land. Elenita’s mother, Lilia, had a conversation
with one Maura Passion (Maura) regarding the sale of the said property.

Believing that Maura was a real estate agent, Lilia borrowed the owner’s copy of the TCT from Elenita and gave it to
Maura. Maura then subdivided the property into several lots from Lot No. 625-A to Lot Through a falsified deed of
sale bearing the forged signature of Elenita and her husband Felicisimo, Maura was able to sell the lots to different
buyers. Maura sold Lot No. 625-K to one Lorna

A few months later, or sometime in August 1990, Lorna sold the lot to petitioner Editha Padlan for P4,000.00.

After learning what had happened, respondents demanded petitioner to surrender possession of Lot No. 625-K, but
the latter refused. Respondents were then forced to file a case before the Regional Trial Court (RTC) of Balanga,
Bataan for the Cancellation of Transfer Certificate of Title

The RTC issued an Order6 denying petitioner’s motion to dismiss and declared her in default. Thereafter, trial
ensued.

On July 1, 2005, the RTC rendered a Decision finding petitioner to be a buyer in good faith and, consequently,
dismissed the complaint.

The CA reversed and set aside the Decision of the RTC and ordered the cancellation of the TCT issued in the name of
Lorna and the petitioner

Aggrieved, petitioner filed a Motion for Reconsideration. Petitioner argued that not only did the complaint lacks
merit, the lower court failed to acquire jurisdiction over the subject matter of the case and the person of the
petitioner.

Issue: WHETHER OR NOT THE HONORABLE COURT HAS JURISDICTION OVER THE SUBJECT MATTER OF THE CASE.

Held: From the Complaint, the case filed by respondent is not simply a case for the cancellation of a particular
certificate of title and the revival of another.

The action is, therefore, about ascertaining which of these parties is the lawful owner of the subject lot, jurisdiction
over which is determined by the assessed value of such lot.

The Court has already held that a complaint must allege the assessed value of the real property subject of the
complaint or the interest thereon to determine which court has jurisdiction over the action

Sec. 33. Jurisdiction of Metropolitan Trial Courts, Municipal Trial Courts and Municipal Circuit Trial Courts in Civil
Cases.―Metropolitan Trial Courts, Municipal Trial Courts, and Municipal Circuit Trial Courts shall exercise: Exclusive
original jurisdiction in all civil actions which involve title to, or possession of, real property, or any interest therein
where the assessed value of the property or interest therein does not exceed Twenty Thousand Pesos (P20,000.00)
or, in civil actions in Metro Manila, where such assessed value does not exceed Fifty Thousand Pesos (P50,000.00)
exclusive of interest, damages of whatever kind, attorney’s fees, litigation expenses and costs

Since the amount alleged in the Complaint by respondents for the disputed lot is only P4,000.00, the MTC and not
the RTC has jurisdiction over the action. Therefore, all proceedings in the RTC are null and void.