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Padlan v. Dinglasan, G.R. No. 180321, March 20, 2013

The case involved a dispute over ownership of a parcel of land originally owned by Elenita Dinglasan. Elenita's mother fraudulently sold portions of the land to different buyers through a real estate agent. Edith Padlan, the petitioner, purchased one portion of land from a previous buyer. Elenita and Felicismo Dinglasan filed a case in RTC to cancel Padlan's title. The RTC dismissed for lack of jurisdiction. The CA reversed, finding Padlan was not a buyer in good faith. The Supreme Court ruled the MTC, not RTC, had jurisdiction as the value of the disputed land, based on the sale to Padlan, did not exceed the MTC's jurisdiction

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48 views2 pages

Padlan v. Dinglasan, G.R. No. 180321, March 20, 2013

The case involved a dispute over ownership of a parcel of land originally owned by Elenita Dinglasan. Elenita's mother fraudulently sold portions of the land to different buyers through a real estate agent. Edith Padlan, the petitioner, purchased one portion of land from a previous buyer. Elenita and Felicismo Dinglasan filed a case in RTC to cancel Padlan's title. The RTC dismissed for lack of jurisdiction. The CA reversed, finding Padlan was not a buyer in good faith. The Supreme Court ruled the MTC, not RTC, had jurisdiction as the value of the disputed land, based on the sale to Padlan, did not exceed the MTC's jurisdiction

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I took her to my penthouse and i freaked it
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Case Name Edith Padlan vs.

Elenita Dinglasan & Felicismo Dinglasan


Topic Componential – Subject Matter
Case No. | G.R. No. 180321 March 20, 2013
Date

Ponente Peralta, J.

RA No. 7691, An Act Expanding the Jurisdiction of the Metropolitan Trial Courts,
Municipal Trial Courts, and Municipal Circuit Trial Courts. Section 3 of RA 7691
expanded the exclusive original jurisdiction of the first level courts to include all civil
Doctrine
actions which involve title to, or possession, of real property, or any interest therein
which does not exceed P20,000 or, in civil actions in Metro Manila, where such assessed
value does not exceed P50, 000.
https://lawphil.net/judjuris/juri2014/nov2014/gr_154291_2014.html
Link

RELEVANT FACTS:
 Elenita Dinglasan was the registered owner of a parcel of land as Lot No.625 under TCT
No. T-105602. While on board of a jeepney, Lilia Baluyot (Elenita’s mother) talked with
Maura Passion about the sale of the subject parcel of land believing that she is real estate
agent.
 Lilia borrowed the title of the land and from her daughter and gave it to Maura where she
divided the land into several parcels from Lot No. 625-A to Lot No. 625-O under Elenita
and her husband Felicismo Dinglasan
 Maura sold the lots to different buyers with a fraudulent deed of sale using falsified
signatures of the owners
 April 26, 1990 – Maura sold Lot No. 625-K to Lorna Ong under TCT No. 134932
 August 1990- Lorna sold the same property to Editha Padlan (the petitioner) for
P4,000.00 cancelling the previous and issued a new one to the petitioner under TCT No.
137466
 Elenita and Felicismo Dinglasan (respondents) found out about the sale and demanded
surrender of the possession of the subject property where petitioner refused.
 Respondents filed a case before the Regional Trial Court of Balanga for Cancellation of
Transfer Certificate of Title No. 137466, where the summons were served to petitioner
through Anita Padlan (petitioner’s mother)
 Respondents moved to declare petitioner in default and prayed to be allowed to present
evidence ex parte
 Petitioner opposed and filed opposition to Declare Defendant in Default with Motion
to Dismiss case for lack of jurisdiction over the person because it was the
petitioner’s mother who received the summons.

RTC Ruling: Dismissed and found petitioner to be a buyer in good faith


 Respondents appealed before the CA
CA Ruling: Found Lorna to be a buyer in bad faith and that petitioner should have conducted
further inquiry on the sale of subject property. The issued title to Lorna and Editha was
fraudulently issued. CA Reversed the decision of the RTC and ordered revival of Editha and
Felicismo’s own title.
 Petitioner appealed before the Supreme Court

ISSUE: Whether the court has jurisdiction over the subject matter

No.
Respondents filed the complaint in 1999, at the time BP 129, the Judiciary Reorganization
Act of 1980, was already amended by RA No. 7691, An Act Expanding the Jurisdiction of the
Metropolitan Trial Courts, Municipal Trial Courts, and Municipal Circuit Trial Courts.
Section 3 of RA 7691 expanded the exclusive original jurisdiction of the first level courts to
include all civil actions which involve title to, or possession, of real property, or any interest
therein which does not exceed P20,000 or, in civil actions in Metro Manila, where such
assessed value does not exceed P50, 000.

Basic as hornbook principle is that jurisdiction over the subject matter of a case is conferred
by law and determined by the allegations in the complaint where the plaintiff’s cause of
action are stipulated.

In the present case, the only basis of valuation of the subject property is the value alleged in
the complaint that the lot was sold in the amount of P4, 000. No tax declaration was even
presented that would show the valuation of the subject property. Since the amount alleged is
only P4, 000, the MTC and not the RTC has jurisdiction over the action.

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