Glynna Foronda-Crystal v. Aniana Lawas Son G.R.

No 221815
Wednesday, September 15, 2021 10:08 PM

Source:
>G.R. No. 221815, November 29, 2017 - GLYNNA FORONDA-CRYSTAL, Petitioner, v. ANIANA LAWAS
SON, Respondent.: (chanrobles.com)>G.R. No. 221815, November 29, 2017 - GLYNNA FORONDA-
CRYSTAL, Petitioner, v. ANIANA LAWAS SON, Respondent.: (chanrobles.com)

Facts:
The petitioner and respondent are arguing over the ownership of a certain parcel of land.

The petitioner assails that the lot was originally her father's which was given to him through a free
patent. The respondent alleges that for twelve and a half years, she has been the lawful owner and
possessor of the subject lot which she purchased for a sum of P200,000.00. According to her, she has
been religiously paying real property taxes thereon as evidenced by a Tax Declaration which was
issued under her name.

The petitioner filed a motion to dismiss the case at the RTC for lack of jurisdiction, stating that as the
market value of the lot as evidenced by the tax declaration is only 2,830.00, the case should have
been filed at the MTC.

The respondent filed a motion for reconsideration at the same court, which granted it and set aside
its previous ruling. The basis of the reconsideration was

(1) Paragraph III of the Complaint stated that the property was worth P200,000.00;
(2) the Court has "judicial knowledge that under the BIR zonal valuation, the property located at
Magay, Compostela, Cebu carries the value that may summed (sic) up to more than P20,000.00 for
the property with an area of 1,570 square meters"; and
(3) the "tax declaration, sometimes being undervalued, is not controlling."

Main issue:

whether or not the RTC validly acquired jurisdiction over the case, and whether or not the RTC
decision was void ab initio;

Ruling:

On the Issue of Jurisdiction

Jurisdiction is defined as the power and authority of a court to hear, try, and decide a case.16 In
order for the court or an adjudicative body to have authority to dispose of the case on the merits, it
must acquire, among others, jurisdiction over the subject matter. It is axiomatic that jurisdiction over
the subject matter is the power to hear and determine the general class to which the proceedings in
question belong; it is conferred by law and not by the consent or acquiescence of any or all of the
parties or by erroneous belief of the court that it exists.

In the Judicial Reorganization Act, real property cases where the subject matter of the case is valued
higher than 20,000 pesos, the case falls in the jurisdiction of the RTC. In Metro Manila, the value
should be more than 50,000 to be within the jurisdiction of the RTC. In determining this, the
assessed value should be followed.

It is a hornbook doctrine that the court should only look into the facts alleged in the complaint to
determine whether a suit is within its jurisdiction.

Since the petitioners failed to allege the assessed value of the property in question, it was for that

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Since the petitioners failed to allege the assessed value of the property in question, it was for that
reason that the case was dismissed originally by the RTC. This is because absent any allegation in
the complaint of the assessed value of the property, it cannot be determined whether the RTC or the
MTC has original and exclusive jurisdiction over the petitioner's action.

However, there are exceptions to this rule:

The court ruled that In the interest of justice, failure to allege the real property's assessed value in
the complaint would not be fatal if, in the documents annexed to the complaint, an allegation of the
assessed value could be found.

The rule on determining the assessed value of a real property, insofar as the identification of the
jurisdiction of the first and second level courts is concerned, would be two-tiered:

First, the general rule is that jurisdiction is determined by the assessed value of the real
property as alleged in the complaint; and

Second, the rule would be liberally applied if the assessed value of the property, while not
alleged in the complaint, could still be identified through a facial examination of the
documents already attached to the complaint.

The Court also held that, in the absence of an allegation of assessed value in the complaint,
the Court shall consider the alleged market value to determine jurisdiction. However the alleged
value must still be included in the complaint.

While the complaint did not contain an assessed value, the tax declaration included in the annex
showed that the property was valued at 2,826.00, which is in the jurisdiction of the MTC so the
decision of the RTC is null and void. Rendering judgement on a case that does not fall within its
jurisdiction under the law is tantamount to usurpation.

Thus, considering the foregoing, it would be proper for

the Court to immediately dismiss this case without prejudice to the parties' filing of a new one
before the MTC that has jurisdiction over the subject property.

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