JOAQUIN BERBANO v. HEIRS OF ROMAN TAPULAO

FACTS:

Respondents, the Heirs of Roman Tapulao, filed a Complaint for Recovery of Possession and Damages against petitioners, Joaquin Berbano and others. Respondents claimed that their father, Roman Tapulao, was the registered owner of a lot in Taguing, Baggao, Cagayan and that they paid the realty taxes for the said lot. After the death of Roman Tapulao and his wife, respondents caused a relocation survey which revealed that petitioners occupied portions of the lot. Petitioners refused to vacate and return the lot despite several demands. In their Answer, petitioners argued that the original owner of the lot was Felipe Peña and that Joaquin Berbano had been in possession of the lot since Felipe Peña ceded half of it to him in 1954. They also argued that the survey mistakenly included Joaquin's lot when Roman Tapulao registered his adjacent lot. Roman Tapulao and his wife acknowledged the error through an Affidavit and promised to respect Joaquin's ownership of that specific portion. The trial court rendered a judgment in favor of the respondents, declaring them as the rightful owners of the lot and ordering petitioners to vacate the portion they occupy. Petitioners filed a motion for reconsideration, raising the issue of jurisdiction for the first time. The trial court denied the motion, stating that the assessed value of the lot was over P20,000 and fell within its jurisdiction. On appeal, the Court of Appeals affirmed the decision, holding that the trial court had jurisdiction because the assessed value of the whole lot was over P20,000. Petitioners filed a Petition for Review on Certiorari before the Supreme Court, arguing that only the assessed value of the specific portion they occupy should be considered for jurisdictional purposes.

ISSUES:

  1. Whether or not the trial court had jurisdiction over the case based on the assessed value of the disputed portion of the lot.

  2. Whether or not the trial court's decision declaring respondents as the rightful owners of the subject property and ordering petitioners to vacate the occupied portion is valid.

RULING:

  1. The trial court had jurisdiction over the case. The Court of Appeals affirmed the trial court's ruling that the assessed value of the entire lot, which is more than P20,000.00, is the determining factor for jurisdiction. The fact that only a portion of the lot is in dispute does not affect the court's jurisdiction.

  2. The trial court's decision declaring respondents as the rightful owners of the subject property and ordering petitioners to vacate the occupied portion is valid. The trial court found that respondents sufficiently proved their ownership of the lot, including the specific portion that petitioners were occupying. The court also ordered petitioners to pay respondents actual damages representing the expenses incurred in filing the case.

PRINCIPLES:

  • Jurisdiction over real property cases is determined by the assessed value of the entire lot, regardless of the specific portion in dispute.

  • The owner of a lot has the right to recover possession of the property and seek damages against those occupying it without authorization.