Editha Padlan vs.

Elenita Dinglasan and Felicisimo Dinglasan

Facts:

Elenita Dinglasan was the registered owner of Lot No. 625 of the Limay Cadastre with an area of 82,972
square meters. Lilia Baluyot , mother of Elenita, talked to Maura Passion about the sale of the land. Lilia,
then, borrowed the owner’s copy of the transfer certificate title from Elenita and gave it to Maura with a
belief that Maura was a real estate agent.

Maura subdivided the property into several lots from Lot No. 625-A to Lot No. 625-0 under the name of
spouses Felicisimo and Elenita Dinglasan, the respondents in this case. She falsified a deed of sale and
forged the signatures of Felicisimo and Elenita to sell the land. Lot No. 625-K was sold to Lorna Ong.
After few months, Lorna sold the land to Editha Padlan, the petitioner, for 4,000 pesos. Transfer
Certificate of Title No. 137466 was issued in favour of the petitioner. Subsequently, they filed a motion
to declare petitioner in default and asked the court to allow them to present evidence ex parte.

After discovering about the sale of their property, the spouses Dinglasan demanded Editha to surrender
possession of the lot but Editha refused. The spouses, then, filed a case for the Cancellation of Transfer
Certificate of Title No. 137466 before the Regional Trial Court of Balanga, Bataan. Summons were served
to Editha through her mother, Anita Padlan.

Editha filed an opposition to declare defendant in default with motion to dismiss the case for lack of
jurisdiction over her person. She argued that the court has no jurisdiction over her person because
summons were not served validly to her. She said that she was in Japan when they served the summons.

The Regional Trial Court dismissed the complaint after finding that the petitioner is in good faith in
buying the land. Respondents appealed before the Court of Appeals. The CA reversed the decision of the
RTC and it cancelled the transfer certificate of title of Lorna. The Court of Appeals also revived the title
of the respondents. It further ruled that Editha was in bad faith when she bought the disputed land from
Lorna and concluded that her transfer certificate of title is null and void because it was issued
fraudulently.

Petitioner, then, filed a Motion for Reconsideration arguing that the court did not acquire jurisdiction
over the subject matter and over the person of the petitioner. She claimed that the court has no
jurisdiction over the subject matter because the value of the property was only 4,000 pesos. Editha
further argued that she was a buyer in good faith and that it was Maura who defrauded the
respondents.

However, the motion was denied. The Court of Appeals stated that, when the Regional Trial Court
denied her motion to dismiss the case, she did not avail any other remedy and that she only became
interested again when the CA ruled against her.

Issue:

1. WHETHER OR NOT THE HONORABLE COURT HAS JURISDICTION OVER THE PERSON OF THE
PETITIONER.

2. WHETHER THE HONORABLE COURT HAS JURISDICTION OVER THE SUBJECT MATTER OF THE
CASE.
 3. WHETHER OR NOT PETITIONER IS A BUYER IN GOOD FAITH AND FOR VALUE.

Rulings:

The Court ruled that it is the MTC which has jurisdiction over the case and ordered all the
proceedings in the Regional Trial Court null and void. The Court reiterated that jurisdiction is
conferred by law and is determined by the allegations in the complaint.
Section 3 of RA 7691, amending Section 33 of BP Blg. 129, stated that the MTC exercises
exclusive jurisdiction over civil action which involves title to or possession of a property or any
interest therein where the assessed value of the property does not exceed 20,000 pesos or
50,000 pesos in Metro Manila.
It is a rule that the complaint must allege the assessed value of the property in question to know
which court has jurisdiction over the case. In connection to this, the petitioner alleged that the
value of the property is 4,000 pesos. Therefore, the Court ruled that it is the MTC which has
jurisdiction over the case.
(Other issues raised by the petitioner were not discussed.)
The petition is granted. The decision and resolution of the CA is reversed and set aside. The
decision of the RTC is declared null and void.

Huguete v. Embudo

Facts:

Petitioner spouses Jorge and Yolanda Huguete filed a complaint against spouses Teofredo Amarillo
Embudo and Marites Huguete-Embudo for Annulment of TCT No. 99694, Tax Declaration No. 46493, and
Deed of Sale, Partition, Damages and Attorney’s Fees before the Regional Trial Court of Cebu City,
Branch 7.

The petitioners alleged that Teofredo Amarillo Embudo sold a 50-square meter lot to them for 15,000
pesos. The lot was a portion of Teofredo’s 150-square meter parcel of land known as Lot No. 1920-F-2
located in San Isidro, Talisay, Cebu that he bought from Ma. Lourdes Villaber-Padillo.

Respondents filed a motion to dismiss arguing that the RTC has no jurisdiction over the action because
the assessed value of the property is only 15,000 pesos which falls within the exclusive jurisdiction of the
MTC. The petitioners, on the other hand, filed an opposition to the motion to dismiss claiming that the
subject matter of the case is for the annulment of the deed of sale and partition which is incapable of
pecuniary estimation and, therefore, the RTC has jurisdiction over it.

The RTC dismissed the complaint for lack of jurisdiction. A petition for review was subsequently filed by
the petitioner but it lacks merit.

Issue:

Whether the RTC has jurisdiction over the action.

Ruling:
The Court held in Singsong v. Isabela Sawmill that to determine whether an action is one the subject
matter of which is not capable of pecuniary estimation, this Court must first ascertain the nature of the
principal action or remedy sought. If the complaint is mainly for the recovery of sum of money, the case
is capable of pecuniary estimation. In which case, jurisdiction depends on the assessed value of the
property. But if the recovery of money is only incidental or a consequence to the principal relief, then
action is incapable of pecuniary estimation which falls within the exclusive jurisdiction of the RTC.

The Court ruled that the argument of the petitioners that the complaint is incapable of pecuniary
estimation is not tenable. It further ruled that the nature of the action is not determined by the caption
of the complaint but by the allegations and reliefs prayed for. In the case, the ultimate objective of the
petitioners is to obtain title to real property, therefore, it should be filed in the proper court having
jurisdiction over the assessed value of the property.

The petition is denied.

VICTORINO QUINAGORAN vs. COURT OF APPEALS

Facts:

The heirs of Juan dela Cruz, represented by Senen dela Cruz, filed a Complaint for Recovery of Portion of
Registered Land with Compensation and Damages against Victorino Quinagoran before the Regional
Trial Court Branch XI of Tuao, Cagayan. The heirs of Juan dela Cruz, the respondents, alleged that they
are the co-owners of the 13,100-square meter land at Centro, Piat, Cagayan, which they inherited from
the late Juan dela Cruz. They also alleged that Quinagoran, the petitioner in this case, started occupying
400 square meter of the land in the mid 70’s by tolerance of respondents. The respondents asked the
petitioner to vacate the land because they planned to build commercial building but the petitioner
refused and he is now claiming ownership over the subject land. They further alleged that they suffered
damages for failure to use the property.

Respondents prayed for reconveyance and surrender of the 400 square meter land and to be paid
₱5,000.00 monthly until the property is vacated, attorney's fees of ₱20,000.00, costs of suit and other
reliefs and remedies.

Quinagoran filed a petition to dismiss on the ground of lack of jurisdiction. He argued that the assessed
value of the land he is occupying is ₱1,730.00 which falls within the exclusive jurisdiction of the MTC.
But the petition was denied. Subsequently, he filed a Motion for Reconsideration but the same was also
denied. He, then, filed a Petition for Certiorari and Prohibition seeking the annulment of the Orders of
the RTC before the Court of Appeals. The Court of Appeals affirmed the decision of the Regional Trial
Court.

Issue:

1. Whether RTC has jurisdiction over all cases of recovery of possession regardless of the value of
the property involved.
2. Whether the complaint must allege the assessed value of the property in question.

Ruling:
1. No, the RTC does not have jurisdiction over all cases of possession. Republic Act No.
769123 which amended Batas Pambansa Blg. 129 and which was already in effect when
respondents filed their complaint with the RTC on October 27, 1994, expressly provides that the
Regional Trial Court shall exercise exclusive jurisdiction over all civil actions which involve the
title to or possession of, real property, or any interest therein, where the assessed value of the
property involved exceeds ₱20,000.00 or₱50,000.00 in Metro Manila. However, if the assessed
value of the real property involved does not exceed ₱50,000.00 in Metro Manila, and
₱20,000.00 outside of Metro Manila, the municipal trial court exercises jurisdiction over actions
to recover possession of real property.
2. Yes, the complaint must allege the assessed value of the property involved to determine which
court has jurisdiction over the action.
Since there is no alleged assessed value of the property in the complaint, it cannot be
determined whether the RTC or the MTC has original and exclusive jurisdiction over the
petitioner's action. The Court held that the courts cannot take judicial notice of the assessed or
market value of the land.
The Court further ruled that the Jurisdiction of the court does not depend upon the answer of
the defendant or even upon agreement, waiver or acquiescence of the parties. Considering that
the respondents did not allege in their complaint the assessed value of the property, the RTC
erred in denying the motion to dismiss. The Court declared all proceedings in the RTC as null and
void, and the CA erred in affirming the RTC.
The petition is GRANTED.