GR 128922; (March, 2001) (Digest)
G.R. No. 128922 ; March 16, 2001
ELEUTERIA B. ALIABO, ET AL., petitioners, vs. HON. ROGELIO L. CARAMPATAN, Presiding Judge, RTC, Branch 31, Dumaguete City, CARL VICTOR CABRERA, ET AL., respondents.
FACTS
Respondents, the Cabreras, filed an action for recovery of ownership and possession of a parcel of land (Lot 2944-B) against petitioners, the Aliabos, in the Municipal Trial Court (MTC) of Siaton, Negros Oriental. The land had been sold to the Cabreras at a sheriff’s auction to satisfy a monetary judgment in a prior case, Civil Case No. 8058, before the Regional Trial Court (RTC). After the redemption period lapsed and a Final Deed of Sale was issued, the Cabreras allowed the Aliabos to remain on the land under certain conditions. When the Aliabos allegedly violated these conditions by planting sugarcane and claiming ownership, the Cabreras demanded they vacate and subsequently filed the MTC case.
The Aliabos moved to dismiss the MTC case, arguing lack of jurisdiction. They invoked the principle of judicial stability, contending that the RTC which ordered the execution sale in Civil Case No. 8058 retained exclusive jurisdiction to settle all related controversies. The MTC denied the motion, and the RTC, on appeal, dismissed the Aliabos’ appeal, upholding the MTC’s jurisdiction. The Aliabos then elevated the case to the Supreme Court via certiorari.
ISSUE
Whether the Municipal Trial Court has jurisdiction over the action for recovery of ownership and possession of Lot 2944-B.
RULING
Yes, the Municipal Trial Court has jurisdiction. The Supreme Court dismissed the petition, affirming the lower courts. The legal logic is twofold. First, jurisdiction is determined by the nature of the action and the assessed value of the property. The action is one for recovery of ownership and possession (an accion publiciana or reinvindicatoria), and the assessed value of Lot 2944-B was less than P20,000.00, which squarely falls under the exclusive original jurisdiction of the MTC pursuant to Section 33 of Batas Pambansa Blg. 129, as amended.
Second, the principle of judicial stability or non-interference does not apply. The present case is independent of the subject matter in the prior RTC case, Civil Case No. 8058. That case was for Specific Performance and Damages involving different lots (Lots 5758 and 2944-A). Lot 2944-B was merely levied upon and sold at auction to satisfy the monetary judgment in that case. The execution proceedings had long been terminated. The current dispute arises from the violation of the conditions for the Aliabos’ post-sale occupancy, a new cause of action separate from the concluded execution. Therefore, the MTC correctly assumed jurisdiction, and its order denying the motion to dismiss was proper. The case was remanded to the MTC for trial.