GR 195834; (November, 2016) (Digest)
G.R. No. 195834 . November 09, 2016.
GUILLERMO SALVADOR, ET AL., PETITIONERS, V. PATRICIA, INC., RESPONDENT. THE CITY OF MANILA AND CIRIACO C. MIJARES, INTERVENORS-APPELLEES.
FACTS
Petitioners, occupants of improvements along Juan Luna Street, filed a complaint for injunction and quieting of title against respondent Patricia, Inc. They sought to prevent their eviction and to determine ownership of the land they occupied. The City of Manila and an individual occupant, Ciriaco Mijares, intervened, with the City claiming ownership. Both the City and Patricia, Inc. presented genuine Transfer Certificates of Title (TCTs) to their respective properties. The core dispute centered on the exact boundaries between these titled properties, as the occupants’ structures were situated in the contested area. To resolve this, the Regional Trial Court (RTC) appointed geodetic engineers as commissioners. Relying on the majority report of the commissioners, the RTC ruled in favor of the petitioners and the City of Manila, permanently enjoining Patricia, Inc. from evicting the occupants.
The Court of Appeals (CA) reversed the RTC and dismissed the complaint. The CA held that the petitioners, as mere occupants without allegation of ownership in the complaint, lacked the requisite legal or equitable title to maintain an action for quieting of title. It further ruled that the RTC improperly adjudicated a boundary dispute, which is not the proper subject of a quieting of title action, and criticized the court for merely adopting the commissioners’ reports without conducting its own hearings. The petitioners sought review before the Supreme Court.
ISSUE
Whether the Court of Appeals correctly dismissed the complaint for injunction and quieting of title.
RULING
No, the Supreme Court reversed the CA but ultimately dismissed the complaint on a different, jurisdictional ground. The Court clarified that an action for quieting of title can be brought by one in possession claiming ownership, and the RTC’s referral to commissioners was a proper exercise of its discretion to ascertain facts. However, the Court identified a fatal jurisdictional defect. The complaint was a real action affecting title to real property. Jurisdiction over such actions is determined by the assessed value of the property involved, as alleged in the complaint. The petitioners’ complaint was completely silent on the assessed value of the subject property. This omission deprived the trial court of the basis to determine whether it had original jurisdiction or whether the case should have been filed with the Metropolitan Trial Court. Consequently, the RTC never acquired jurisdiction over the case from its inception. The dismissal of the complaint by the CA was affirmed, but solely on the ground of the RTC’s lack of jurisdiction due to the failure to allege the property’s assessed value in the complaint.