FORONDA-CRYSTAL vs SON

G.R. No. 221815, November 29, 2017

Foronda-Crystal is the daughter of the registered owner who derived his title over the
property in Compostela, Cebu from a successful grant of a Free Patent covered by OCT
No. OP-37324.
On March 15, 1999, Aniana Son filed an action for reconveyance and damages before
the RTC of Mandaue City against the petitioner alleging that the respondent has been
the lawful owner and possessor of the subject property. She also alleged that she
acquired the said property from a certain Eleno Arias through sale for P200,000.00 and
has been religiously paying real estate taxes as evidenced by a tax declaration issued
to her. The respondent contested that the issuance of Free Patent to the petitioner was
due to gross error or any other cause as the latter was alleged that there is no proof of
tax declaration to support her predecessor in interest’s ownership of the said property.
On April 13, 1999, the petitioner filed a motion to dismiss on the grounds of (1) lack of
jurisdiction; (2) venue is improperly laid; (3) action has prescribed; and (4) lack of cause
of action. The case was dismissed by the RTC for lack of jurisdiction whereby the
market value of the property in question per its tax declaration is P2,830.00 which within
the jurisdiction of the Municipal Circuit Trial Court of Liloan-Compostela, Cebu.
However, upon the respondent’s motion, RTC reconsidered and set aside its prior ruling
based on the following reasons:
1) The property was worth P200,000.00
2) The court has judicial knowledge that the property may summed up to more than
P200,000.00 with an area of 1570 sq. m., under the BIR zonal valuation; and
3) Tax declaration, sometimes being undervalued, is not controlling.
On November 24, 2006, the RTC ruled in favor of the respondent and the Register of
Deeds of Cebu was ordered to cancel the property’s title certificate under the
petitioner’s name and issue the same under the name of the respondent.
The petitioner appealed the case to the Court of Appeals and alleged the following:
 1) RTC rendered its decision with undue haste considering that the same was
promulgated even before the expiration of the period within which the parties'
respective memoranda were to be filed;
2) Respondent was not able to prove that the lot she acquired from Arias was Lot
No. 1280;
3) Respondent failed to prove that she was in actual physical possession of the
subject property whereas the petitioner was able to do so since 1972;
4) RTC erred in its order to cancel OCT No. OP-37324 and to issue, in lieu thereof,
a new title in herein respondent's name; and
5) the action filed by the respondent was already barred by prescription and laches.
The CA denied the appeal and affirmed the RTC decision dated November 2006. The
respondent moved for reconsider, but denied. Hence, petitioned for review on certiorari
under Rule 45 of the Rules of Court.
The issue in this case is whether the RTC validly acquired jurisdiction over the case or
not.
The Supreme Court held that the RTC lacked jurisdiction over the case by reason of the
complainant failed to allege in her complaint the assessed value of the subject property.
Rather, she alleged the property’s market value amounting to P200,000.00. However,
the acquisition of the jurisdiction over the case involving subject property shall be
determined by assessed value thereof in which the complainant should aver the same.
Otherwise, the case shall be dismissed. Without the allegation of the assessed value of
the property, the determination of which court has jurisdiction over the case. Since there
is no allegation of the assessed value of the subject property, the two-tiered rule shall
apply to this case.
The rule on determining the assessed value of a real property, insofar as the
identification of the jurisdiction of the first and second level courts is concerned, would
be a) that jurisdiction is determined by the assessed value of the real property as
alleged in the complaint; and b) 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.
Herein, the tax declaration attached to the complaint contained the assessed value of
the real property as it revealed that its value at P2,826.00. Hence, the MTC has
jurisdiction of the case, not the RTC.
Under the BP 129, Metropolitan Trial Courts, Municipal Trial Courts, and Municipal
Circuit Trial Courts have exclusive original jurisdiction over 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 does not exceed P20,000,00 or, for civil actions in Metro
Manila, where such value not exceeding P50,000.00.