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NILO PADRE v. FRUCTOSA BAILLO

FACTS:

On October 13, 1986, the RTC of Allen, Northern Samar, Branch 23, decided in favor of the plaintiffs Fructosa Badillo and others in Civil Case No. A-514 for Ownership and Recovery of Possession with Damages against the defendants, including Consesa Padre. The court declared the plaintiffs as the lawful owners of a five-sixth portion of Lot No. 4080 and ordered the defendants to vacate the premises and pay rent and damages to the plaintiffs. This decision became final and executory on November 5, 1986. Subsequently, on December 29, 1997, the Badillo family filed another complaint for ownership and possession against those occupying their property, including some defendants from the previous case. The new case was filed with the MTC of San Isidro, Northern Samar, and was docketed as Civil Case No. 104. Nilo Padre, the heir of Consesa Padre, who had died in 1989, was impleaded as a defendant and was declared in default for failing to file an answer. The Badillo family alleged that the defendants reoccupied the property in 1990 after execution of the judgment in Civil Case No. A-514 and refused to vacate despite repeated demands, prompting them to file Civil Case No. 104.

ISSUES:

  1. Whether the RTC correctly affirmed the MTC ruling that it has jurisdiction over Civil Case No. 104.

RULING:

  1. The Supreme Court ruled that the MTC had no jurisdiction over Civil Case No. 104, as the case involved a real property with an assessed value exceeding the jurisdictional limit of the MTC. The proper jurisdiction belonged to the RTC since the assessed value of the property was P26,940.00, and the action filed was for accion publiciana.

PRINCIPLES:

  1. Certiorari - The existence and availability of the right of appeal proscribes a resort to certiorari. However, it is allowed as an exception when the writs issued are null and void or when the questioned order amounts to an oppressive exercise of judicial authority.

  2. Jurisdiction - The nature of the action and the determination of which court has jurisdiction are based on the allegations in the complaint and the character of the relief sought. For civil cases involving realty outside Metro Manila, the MTC has exclusive original jurisdiction only if the assessed value does not exceed P20,000.00.

  3. Accion Publiciana - This is an ordinary civil proceeding to determine the better right of possession of realty independently of title. It is filed after the expiration of one year from the accrual of the cause of action or from the unlawful withholding of possession of the realty.

  4. Judgment on Jurisdiction - A decision rendered by a court without jurisdiction is null and void, and can never become final and executory. It can be attacked directly or collaterally.

  5. Timeliness of Certiorari Petitions - If a petition is filed via registered mail, the date of mailing, as stamped on the envelope or the registry receipt, is considered as the date of filing.