De Vera, et. al. v. Santiago Sr., et. al.
G. R. No. 179457
June 22, 2015
FACTS:
Petitioners filed an action for reconveyance of ownership or possession with damages
against respondents before the Municipal Trial Court (MTC) of Bolinao, Pangasinan.
Petitioners alleged that they are the owners of certain portions of a subdivided land
located at Barangay Patar, Bolinao, Pangasinan, with an area of about 265,342 square
meters, denominated as Lot No. 7303. They also alleged that they had been in actual
and continuous possession and occupation of their respective portions of the land since
1967, without disturbance from any third person. However, they discovered that their
respective lots covered by Lot No. 7303 were already covered by Free Patent Titles in
the names of respondents, which were acquired through manipulation,
misrepresentation, fraud, and deceit. Petitioners also claimed that their open,
continuous, and exclusive possession of the land for at least a period of 30 years prior
to the issuance of the Free Patent Titles, ipso jure converted it into a private property.
Further, they allege that the Bureau of Lands has no jurisdiction to issue the said titles.
In support of their claims, petitioners attached to their complaint copies of their
respective tax declarations and prayed to be declared as absolute owners of Lot No.
7303, for respondents to reconvey to them the whole area of the lot, and for the award
of actual, moral, and exemplary damages, and litigation expenses.
Respondents denied the material allegations in petitioners' complaint and countered
that they are the owners of the land denominated as Lot No. 7303. They insisted that
their acquisition of titles over the land was regular and done in accordance with the law.
They also claimed that they and their predecessors-in-interest are the actual
possessors and owners of the disputed land as shown by their titles and tax
declarations.
Respondents alleged that the MTC has no jurisdiction over the case. As the combined
assessed value of the disputed land is more than P20,000.00, the case is within the
exclusive original jurisdiction of the RTC pursuant to Section 19(2) of B.P. Blg. 129,
known as the Judiciary Reorganization Act of 1980, as amended by Republic Act No.
7691. They also alleged that titles over Lot No. 7303 has already acquired the status of
indefeasibility as they were issued as early as 1996, and they were also issued tax
declarations over their titled properties. They claimed to have acquired the land from
Eugenio Santiago, Sr., as shown in the Deeds of Sale which were all duly registered
with the Register of Deeds in 1991 and 1992. They noted that the only documents of
petitioners are tax declarations which were issued as "new" in 1990 without any proof of
acquisition, hence, inferior to the Original Certificate of Titles and Tax Declarations
issued to respondents. Respondents prayed for the dismissal of the complaint, and to
be declared lawful owners and possessors of the disputed land.
The MTC rendered a Decision dismissing the complaint and declaring the respondents
as the lawful owners and possessors of the land, Lot No. 7303. Petitioners filed an
appeal with the Regional Trial Court or RTC of Pangasinan, Branch 64.
The RTC rendered a Decision in favor of petitioners. Respondents then filed a petition
for review under Rule 42 of the Rules of Court with the Court of Appeals or CA which
was granted, annulling and setting aside the Decisions of the RTC and MTC on the
ground of lack of jurisdiction. The CA declined to resolve and deemed as moot and
academic the other factual issues raised in the petition. The CA denied petitioners’
motion for reconsideration. Hence, the petition for review on certiorari.
ISSUES:
1. Whether or not the MTC has jurisdiction over the case.
2. Whether or not the CA erred in annulling the decision of the RTC on the ground
of lack of jurisdiction.
RULING:
1. No. The MTC has no jurisdiction over the case. Lot No. 7303 located in Bolinao,
Pangasinan has a total assessed value of P54,370.00. In line with Section 19 (2)
and Section 33 (3) of B.P. Blg. 129 as amended, the RTC has jurisdiction over
petitioners' civil action involving title to a real property outside Metro Manila with a
total assessed value in excess of P20,000.00.
2. Yes. The CA erred in annulling the decision of the RTC on the ground of lack of
jurisdiction. Under Section 8, Rule 40 of the Rules of Court, if the MTC tried a
case on the merits despite having no jurisdiction over the subject matter, its
decision may be reviewed on appeal by the RTC. Section 8 specifically provides
that “[I]f the case was tried on the merits by the lower court without jurisdiction
over the subject matter, the Regional Trial Court on appeal shall not dismiss the
case if it has original jurisdiction thereof, but shall decide the case in accordance
with the preceding section, without prejudice to the admission of amended
pleadings and additional evidence in the interest of justice.” Further, the RTC has
appellate jurisdiction over the case and its decision should be deemed
promulgated in the exercise of that jurisdiction. Section 22 of BP 129 provides
the appellate jurisdiction over cases decided by first-level courts, thus, the
amount involved is immaterial for purposes of the RTC's appellate jurisdiction as
all cases decided by the MTC are generally appealable to the RTC irrespective of
the amount involved. Lastly, the RTC not only has exclusive original jurisdiction
over petitioners' action for reconveyance of ownership and possession with
damages, but also appellate jurisdiction over the MTC Decision itself.
