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BARANGAY SAN ROQUE v. HEIRS OF FRANCISCO PASTOR

FACTS:

The petitioner, Barangay San Roque, Talisay, Cebu, filed a Complaint for eminent domain before the Municipal Trial Court (MTC) of Talisay, Cebu (Branch 1) against the respondents, Heirs of Francisco Pastor. The MTC dismissed the Complaint for lack of jurisdiction, stating that an action for eminent domain is within the exclusive original jurisdiction of the Regional Trial Court (RTC).

The petitioner appealed the dismissal to the RTC of Cebu City (Branch 58). However, the RTC also dismissed the Complaint, ruling that the action should have been filed before the MTC since the value of the subject property was less than P20,000. The RTC based its ruling on Section 3, paragraph (3) of Republic Act No. 7691, which provides that civil actions involving title to or possession of real property with an assessed value of less than P20,000 are within the exclusive original jurisdiction of the MTC.

Aggrieved, the petitioner appealed directly to the Supreme Court, raising the issue of which court, MTC or RTC, has jurisdiction over cases for eminent domain where the assessed value of the subject property is below P20,000.

The Supreme Court granted the Petition, ruling that an expropriation suit, which is an action for eminent domain, falls within the jurisdiction of the RTCs under Section 19 (1) of BP 129. It held that an action for eminent domain is incapable of pecuniary estimation, and therefore, falls under the exclusive original jurisdiction of the RTCs, regardless of the value of the subject property.

ISSUES:

  1. Whether the Regional Trial Court (RTC) has jurisdiction over an action for eminent domain.

  2. Whether the assessed value of the subject property determines the jurisdiction of the court.

RULING:

  1. Yes, the RTC has jurisdiction over an action for eminent domain. Section 19 (1) of BP 129 provides that RTCs shall exercise exclusive original jurisdiction over "all civil actions in which the subject of the litigation is incapable of pecuniary estimation." The Court held that an expropriation suit falls under this category as it involves the exercise of the right to eminent domain, which is incapable of pecuniary estimation.

  2. No, the assessed value of the subject property does not determine the jurisdiction of the court in an action for eminent domain. The Court rejected the argument that the action should have been brought before the Municipal Trial Court (MTC) based on the assessed value of the property. It clarified that the assessed value is only relevant in determining the jurisdiction of the court in cases involving title to or possession of real property, but not in an eminent domain suit.

PRINCIPLES: