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GLYNNA FORONDA-CRYSTAL v. ANIANA LAWAS SON

FACTS:

The petitioner in this case is the daughter of Eddie Foronda, the registered owner of a parcel of land located in Barrio Magay, Municipality of Compostela, Province of Cebu. The respondent, Aniana Lawas Son, filed an action for reconveyance and damages against the petitioner, claiming that she has been the lawful owner and possessor of the subject lot for twelve and a half years. The respondent alleged that she purchased the land from a certain Eleno T. Arias.

The petitioner filed a motion to dismiss, but the trial court initially dismissed the case for lack of jurisdiction. However, the trial court later reversed its ruling and the case proceeded to trial. The trial court rendered a decision in favor of the respondent, ordering the cancellation of the petitioner's title and the issuance of a new title in the respondent's name. The petitioner appealed to the Court of Appeals, but the appellate court affirmed the trial court's decision. The petitioner filed a petition for review on certiorari before the Supreme Court.

This petition for review on certiorari under Rule 45 of the Rules of Court raises several issues. The petitioner argues for the reversal of the challenged decision on grounds such as lack of jurisdiction, void proceedings and judgment, applicability of Article 434 of the Civil Code, and whether the property was a public grant. The petitioner also contends that the action is barred by prescription and questions the validity and integrity of the RTC decision because it was rendered with undue haste. The main issues raised by the petitioner are: (1) whether the RTC had jurisdiction over the case and if the RTC decision was void; (2) whether the petitioner's father's title should be canceled based on the respondent's ownership allegations; and (3) whether the action is barred by prescription.

The petition is deemed meritorious. Jurisdiction is defined as the power and authority of a court to hear, try, and decide a case. The distinction between the jurisdiction of the RTC and the first-level courts (MeTC, MTC, MCTC, MTCC) is based on the assessed value of the property involved. According to relevant provisions in the Judiciary Reorganization Act of 1980, as amended, the RTC has exclusive jurisdiction over civil actions involving title to or possession of real property if the assessed value exceeds P20,000.00. The assessed value, not fair market value, determines jurisdiction. Several cases have upheld this interpretation of the law.

ISSUES:

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

  2. Whether or not the Original Certificate of Title issued under the name of petitioner's father should be cancelled and set aside based on respondent's allegations of ownership over the same.

  3. Whether or not the action is already barred by prescription.

RULING:

The petition is impressed with merit.

On the Issue of Jurisdiction

The RTC did not validly acquire jurisdiction over the case since the assessed value of the property was below the threshold amount that would confer jurisdiction to the RTC. Consequently, the RTC decision is void ab initio. As the complaint referred to an attached tax declaration revealing the property’s assessed value was P2,826.00, it was the MTC, not the RTC, that had jurisdiction over the case. The RTC should have upheld its earlier order dismissing the case. All proceedings and decisions rendered by the RTC are therefore null and void.

Other issues raised are not discussed further due to the ruling on jurisdiction.

PRINCIPLES:

  1. Jurisdiction over the subject matter is conferred by law and cannot be waived by any party.

  2. In determining the court's jurisdiction in cases involving real property, the assessed value, not the market value, must be alleged in the complaint.

  3. A complaint lacking an allegation of the assessed value of the property is generally subject to dismissal.

  4. The Judiciary Reorganization Act of 1980 differentiates jurisdiction between the RTC and MTC based on the assessed value of the property.

  5. A liberal interpretation of rules may be applied where the assessed value can be determined from annexed documents, even if not expressly stated in the complaint.

  6. Decisions rendered by a court without proper jurisdiction are null and void.