GR 212413; (June, 2018) (Digest)
G.R. No. 212413 . June 06, 2018.
MA. ROSARIO AGARRADO, ET AL., PETITIONERS, V. CRISTITA LIBRANDO-AGARRADO AND ANA LOU AGARRADO-KING, RESPONDENTS.
FACTS
The petitioners are legitimate children of the late spouses Rodrigo and Emilia Agarrado, who owned a 287-square-meter lot in Bacolod City. After Emilia died intestate in 1978, Rodrigo later married respondent Cristita, with whom he had a child, respondent Ana Lou, who was conceived during Rodrigo’s first marriage but born after Emilia’s death. Upon Rodrigo’s death in 2000, Cristita and Ana Lou filed a complaint for partition before the Regional Trial Court (RTC) of Bacolod City against the petitioners and other unnamed heirs. The RTC ordered the partition of the property, a decision affirmed with modification by the Court of Appeals (CA), which specified the co-ownership shares. The petitioners elevated the case, raising multiple issues including the determination of compulsory heirs and the proper computation of shares.
ISSUE
The core issue resolved by the Supreme Court was whether the RTC properly acquired jurisdiction over the action for partition, considering the failure of the complaint to allege the assessed value of the subject property.
RULING
The Supreme Court granted the petition and dismissed the complaint for lack of jurisdiction. The Court clarified that while an action for partition is incapable of pecuniary estimation, jurisdiction over such an action is determined by the assessed value of the property involved, pursuant to Sections 19(2) and 33(3) of Batas Pambansa Blg. 129, as amended. Jurisdiction is conferred by law based on this valuation, which dictates whether the case falls under the exclusive original jurisdiction of the first-level courts (Metropolitan Trial Courts, etc.) or the second-level courts (Regional Trial Courts). The complaint filed by the respondents failed to allege the assessed value of the property, nor was this information provided in any attached document. Following the precedent in Foronda-Crystal v. Son, such failure is fatal as it prevents the court from determining whether it has the requisite jurisdiction. Consequently, the RTC did not acquire jurisdiction over the case. The Supreme Court set aside the decisions of the lower courts and dismissed the complaint without prejudice to its refiling in the proper court. The resolution of this jurisdictional issue rendered a discussion of the other substantive issues raised by the petitioners unnecessary.