View full case

JOSEPH O. REGALADO v. EMMA DE LA RAMA VDA. DE LA PENA

FACTS:

The dispute in this case involves two parcels of land located in Murcia, Negros Occidental. The respondents are the registered owners of the properties, while the petitioner entered and took possession of them without their knowledge and consent. The respondents discovered this illegal entry in 1995 and demanded that the petitioner vacate the properties, but he refused. The parties attempted to settle the matter at the Barangay Office but were unsuccessful. As a result, the respondents filed a complaint for recovery of possession and damages with injunction against the petitioner.

In his defense, the petitioner claimed that the respondents had waived their rights and interests over the properties in favor of Jaime, who subsequently waived them in favor of the petitioner. The petitioner filed a motion to dismiss the case, arguing that the Regional Trial Court (RTC) has no jurisdiction and that it should be filed with the proper Municipal Trial Court (MTC). However, the RTC denied the motion and ruled in favor of the respondents, ordering the petitioner to turn over the properties and pay attorney's fees.

Both parties appealed to the Court of Appeals (CA), which affirmed the RTC decision. Unsatisfied with the CA decision, the petitioner now seeks a review from the Supreme Court, raising issues regarding the jurisdiction of the RTC and the return of possession of the properties to the respondents.

ISSUES:

  1. Whether the Regional Trial Court (RTC) had jurisdiction over the case.

  2. Whether the tax declarations of the properties were necessary to determine jurisdiction.

  3. Whether the Complaint is considered an action for ejectment or accion publiciana.

  4. Whether the assessed value of the properties was necessary to determine jurisdiction.

  5. Whether or not the action filed by the respondents is an ejectment case.

  6. Whether or not the RTC has jurisdiction over the case.

RULING:

  1. The RTC did not have jurisdiction over the case.

  2. The tax declarations of the properties were not necessary to determine jurisdiction.

  3. The Complaint is considered an action for accion publiciana.

  4. The assessed value of the properties was necessary to determine jurisdiction.

  5. The action filed by the respondents is not an ejectment case as it failed to meet the jurisdictional requirements for either forcible entry or unlawful detainer.

  6. The RTC does not have jurisdiction over the case as the Complaint failed to specify the assessed value of the subject properties, thereby making it unclear which court has exclusive original jurisdiction. All proceedings before the RTC, including its decision, are void due to lack of jurisdiction.

PRINCIPLES:

  • There are three kinds of action for recovery of possession of real property: ejectment (either for unlawful detainer or forcible entry), accion publiciana, and accion reinvindicatoria.

  • The proper Metropolitan Trial Court (MeTC), MTC, or Municipal Circuit Trial Court (MCTC) has exclusive original jurisdiction over ejectment cases.

  • The RTC has exclusive original jurisdiction over civil actions involving title to or possession of real property if the assessed value exceeds a certain amount.

  • Jurisdiction is determined not only by the type of action but also by the assessed value of the property.

  • The pertinent portions of the complaint are the basis for determining the nature of the action and the court that can take cognizance of the case.

  • Special jurisdictional facts must be set forth in a complaint for ejectment.

  • R.A. 7691 provides that an action for forcible entry or unlawful detainer must be filed within one year from the time the owner or legal possessor learned of their dispossession.

  • Jurisdiction is conferred only by law and cannot be presumed or implied. It must distinctly appear from the law and cannot be vested upon a court by agreement of the parties or a court's erroneous belief of jurisdiction.

  • The assessed value of the subject properties must be alleged to ascertain which court has jurisdiction over the case.

  • Courts cannot simply take judicial notice of the assessed value or market value of land. Lack of jurisdiction renders all proceedings before the court, including its decision, void.

  • Courts are duty-bound to render accurate decisions that clearly and distinctly express the facts and law on which they are based.