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HEIRS OF LATE SPS. ALEJANDRO RAMIRO v. SPS. ELEODORO

FACTS:

The respondent spouses filed a case against the petitioners, claiming that they were the registered owners of a property and that the petitioners forcibly dispossessed them of the said property. The petitioners, on the other hand, denied the allegations and raised affirmative defenses in their defense. After the trial, the Regional Trial Court (RTC) ruled in favor of the respondents, declaring the Deed of Sale valid and directing the defendants to execute a Deed of Extra-Judicial Partition. Dissatisfied with the decision, the petitioners filed an appeal with the Court of Appeals (CA), arguing that the RTC did not have jurisdiction over the case. However, the CA dismissed the appeal, upholding the jurisdiction of the RTC. The petitioners then filed a motion for reconsideration, which was subsequently denied by the CA. Consequently, the petition for review on certiorari was filed with the Supreme Court, raising several issues including jurisdiction, the existence of an equitable mortgage, and the applicability of the doctrine of laches.

ISSUES:

  1. Whether the RTC acquired jurisdiction over the subject matter of the action.

  2. Whether the Deed of Sale dated October 20, 1991 should be treated as an equitable mortgage.

  3. Whether the spouses Bacaron's claims are barred by laches.

RULING:

  1. Whether the RTC acquired jurisdiction over the subject matter of the action.

    No. The Supreme Court found that the action primarily involves title to or possession of real property, and thus, jurisdiction should be based on the assessed value of the property. Since the respondents did not allege the assessed value of the property, the RTC did not acquire jurisdiction over the subject matter. Consequently, all proceedings before the RTC are declared null and void.

  2. Whether the Deed of Sale dated October 20, 1991 should be treated as an equitable mortgage.

    Not discussed due to the resolution of the jurisdictional issue.

  3. Whether the spouses Bacaron's claims are barred by laches.

    Not discussed due to the resolution of the jurisdictional issue.

WHEREFORE, the petition is GRANTED. The Decision dated October 19, 2010 and Resolution dated May 3, 2011 of the Court of Appeals in CA-G.R. CV No. 01350-MIN are hereby REVERSED and SET ASIDE. The Decision of the Regional Trial Court dated July 13, 2007 is declared NULL and VOID. The amended complaint in Civil Case No. 1966 (045) is dismissed without prejudice.

SO ORDERED.

PRINCIPLES:

  • Jurisdiction of courts over civil actions involving real property is determined by the material allegations of the complaint and the assessed value of the property.

  • Actions primarily involving title to or possession of real property require the assessed value to determine jurisdiction.

  • The court cannot take judicial notice of the assessed value of real property.

  • Proper payment of docket fees based on the nature of the complaint and the assessed value of the property is necessary for the trial court to acquire jurisdiction.

  • Complaints not alleging the assessed value of the property must be dismissed for improper determination of court jurisdiction.