BARANGAY PIAPI v. IGNACIO TALIP REPRESENTING HEIRS OF JUAN JAYAG

FACTS:

Petitioners filed a complaint for reconveyance and damages against respondent, alleging that they and their predecessors-in-interest have possessed a parcel of land for more than 30 years. The land was covered by an Original Certificate of Title (OCT) issued in the name of Juan Jayag. Respondent fraudulently obtained a Transfer Certificate of Title (TCT) in his name and threatened to build a fence around the land. The assessed value of the land was P41,890.00.

Respondent moved to dismiss the complaint for lack of jurisdiction, citing that the Municipal Circuit Trial Court has exclusive jurisdiction because the assessed value of the land is only P6,030.00. The trial court granted the motion to dismiss, and the motion for reconsideration was also denied. Petitioners filed a petition for certiorari to challenge the trial court's dismissal.

ISSUES:

  1. Whether the Regional Trial Court (RTC) has jurisdiction over the complaint for reconveyance.

  2. Whether the assessed value or market value of the land is the basis for determining jurisdiction.

RULING:

  1. The Supreme Court held that the Municipal Circuit Trial Court has jurisdiction over the complaint for reconveyance. The RTC does not have jurisdiction because petitioners failed to allege the assessed value of the property in their complaint as required by law. Jurisdiction is determined based on the allegations in the complaint and the reliefs prayed for. Petitioners only stated the market value of the land, which is P15,000.00. The assessed value of the property is the basis for determining jurisdiction, and since it exceeds P20,000.00, the case falls within the jurisdiction of the Municipal Circuit Trial Court. Therefore, the petition was denied, and the orders of the trial court were affirmed.