Foronda-Crystal v.

Son
G.R. No. 221815
29 November 2017

FACTS :
Foronda-Crystal is the registered owner of a parcel of land in Cebu. Son instituted an action for
reconveyance against Foronda-Crystal before the Regional Trial Court ("RTC"), Mandaue City
alleging that, for twelve and a half years, she has been the lawful owner and possessor of the
subject lot, having purchased the same for P200,000.00.

The complaint did not contain any allegation on the assessed value of the property but a Tax
Declaration under Son’s name was attached thereto, which valued the disputed property at
P2,826.00.

Foronda-Crystal filed a motion to dismiss on the ground of lack of jurisdiction arguing that the
jurisdiction lies with the Municipal Circuit Trial Court ("MCTC").
ISSUE/S :
Whether or not the RTC has jurisdiction over the case?
RULING :
No, the RTC does not have jurisdiction.

In determining the assessed valued of a real property for purposes of jurisdiction, the court has
developed a two-tiered approach:

First, the general rule is that jurisdiction is determined by the assessed value of the real property
as alleged in the complaint; and

Second, the rule would be liberally applied if the assessed value of the property, while not
alleged in the complaint, could still be identified through a facial examination of the documents
already attached to the complaint.

In this instance, the complaint attached a Tax Declaration which contained the assessed value
of the property – P2,826.00. On the basis of this, it is the MCTC that has jurisdiction.

The decision of the RTC is declared null and void for want of jurisdiction. This is without
prejudice to the filing of the parties of the proper action before the proper court.