Quinagoran v CA

Facts:

The heirs of Juan dela Cruz, represented by Senen dela Cruz filed a Complaint for Recovery of Portion of Registered Land with Compensation and Damages against Victorino Quinagoran before the RTC Cagayan. They alleged that they are the co-owners of a  a parcel of land at Centro, Piat, Cagayan, which they inherited from the late Juan dela Cruz.   

Quinagoran started occupying a house on the north-west portion of the property, by tolerance of the heirs. The heirs asked petitioner to remove the house as they planned to construct a commercial building on the property but petitioner refused, claiming ownership over the lot.

The heirs prayed for the reconveyance and surrender of the disputed lot and to be paid the amount of P5,000.00 monthly until the property is vacated.

 Quinagoran filed a Motion to Dismiss claiming that the RTC has no jurisdiction over the case under Republic Act (R.A.) No. 7691, which expanded the exclusive original jurisdiction of the Municipal Trial Court (MTC)  to include all civil actions which involve title to, or possession of, real property, or any interest therein which does not exceed P20,000.00.  He argued that since the lot which he owns adjacent to the contested property has an assessed value of P1,730, the assessed value of the lot under controversy would not be more than the said amount. He likewise avers that it is an indispensable requirement that the complaint should allege the assessed value of the property involved.

The heirs maintain that the contention of petitioner in his Motion to Dismiss before the RTC that the assessed value of the disputed lot is below P20,000.00 is based on the assessed value of an adjacent property and no documentary proof was shown to support the said allegation. It also contended that the tax declaration which petitioner presented, together with his Supplemental Reply before the CA, and on the basis of which he claims that the disputed property's assessed value is only P551.00, should also not be given credence as the said tax declaration reflects the amount of P56,100.or the entire property.

 The RTC denied petitioner's Motion to Dismiss on the basis that the action is accion publicciana and therefore, its jurisdiction lies in the RTC, regardless of the value of the property.  The CA affirmed decision of the RTC.

Issue:

Whether or not the RTC has jurisdiction over all cases of recovery of possession regardless of the value of the property involved?

Held:

NO. Jurisdiction lies in the MTC.

The doctrine that all cases of recovery of possession or accion publiciana lies with the RTC regardless of the value of the property -- no longer holds true.  As things now stand, a distinction must be made between those properties the assessed value of which is below P20,000.00, if outside Metro Manila; and P50,000.00, if within.

         Republic Act No. 7691 expressly provides:

 SEC. 19. Jurisdiction in civil cases – Regional Trial Courts shall exercise exclusive original jurisdiction:

 (2) In all civil actions which involve the title to or possession of, real property, or any interest therein, where the assessed value of the property involved exceeds Twenty thousand pesos (P20,000.00) or, for civil actions in Metro Manila, where such value exceeds Fifty thousand pesos (P50,000.00) except for forcible entry into and unlawful detainer of lands or buildings, original jurisdiction over which is conferred upon the Metropolitan Trial Courts, Municipal Trial Courts, and Municipal Circuit Trial Courts.

            In Atuel v. Valdez,  the Court likewise expressly stated that:

            Jurisdiction over an accion publiciana is vested in a court of general jurisdiction.  Specifically, the regional trial court exercises exclusive original jurisdiction “in all civil actions which involve x x x possession of real property.”  However, if the assessed value of the real property involved does not exceed P50,000.00 in Metro Manila, and P20,000.00 outside of Metro Manila, the municipal trial court exercises jurisdiction over actions to recover possession of real property.

         In the case, Quinagoran maintains that there should be such an allegation of the assessed value of the real property to determine jurisdiction. However, nowhere in said complaint was the assessed value of the subject property ever mentioned.  There is therefore no showing on the face of the complaint that the RTC has exclusive jurisdiction over the action of the respondents. Absent any allegation in the complaint of the assessed value of the property, it cannot be determined whether the RTC or the MTC has original and exclusive jurisdiction over the petitioner's action. The courts cannot take judicial notice of the assessed or market value of the land.

        Considering that the respondents failed to allege in their complaint the assessed value of the subject property, the RTC seriously erred in denying the motion to dismiss.  Consequently, all proceedings in the RTC are null and void. The CA also erred in affirming the RTC.