G.R. No. 272300, April 07, 2025
REYNALDO SAN PEDRO [DECEASED AND SUBSTITUTED BY HIS SON, RAYMONDE SAN PEDRO] AND OTHER PERSONS ACTING IN HIS BEHALF, PETITIONERS, VS. SPOUSES ANGELITO TRINIDAD AND CONSUELO TRINIDAD, RESPONDENTS.

FACTS

Spouses Angelito and Consuelo Trinidad filed a forcible entry case against Reynaldo San Pedro before the Municipal Trial Court (MTC) of Sta. Rosa, Nueva Ecija. They alleged ownership of a parcel of land by virtue of a Deed of Absolute Sale executed by Reynaldo and that Reynaldo, through force and stealth, entered and took possession of the property in April 2016. Reynaldo countered that he had been in continuous, actual possession of the property. The MTC dismissed the case, finding the spouses failed to prove prior physical possession. On appeal, the Regional Trial Court (RTC) determined the MTC lacked jurisdiction over the subject matter, as the assessed values of buildings on the property placed it within the RTC’s jurisdiction. Applying Rule 40, Section 8 of the Rules of Court, the RTC treated the case as an accion publiciana, tried it anew, and rendered a Decision ordering Reynaldo to vacate the property. Reynaldo filed a Notice of Appeal to the Court of Appeals (CA). The CA dismissed the appeal, ruling it was an improper mode. The CA held that since the RTC Decision was rendered in the exercise of its appellate jurisdiction, the proper remedy was a petition for review under Rule 42, not an ordinary appeal by notice of appeal.

ISSUE

Whether the Court of Appeals erred in ruling that the appropriate mode of appeal from the Regional Trial Court’s Decision was a petition for review instead of an ordinary appeal.

RULING

No, the Court of Appeals did not err. The petition is bereft of merit. The Supreme Court affirmed the CA Resolutions. The RTC Decision was rendered in the exercise of its appellate jurisdiction. Although the RTC tried the case on the merits pursuant to Rule 40, Section 8 after finding the MTC lacked jurisdiction, this did not convert its jurisdiction from appellate to original. The phrase “as if the case was originally filed with it” is a procedural mechanism for convenience and judicial economy but does not alter the nature of the RTC’s jurisdiction, which remains appellate because the case reached it via an appeal from the MTC. Consequently, under Rule 41, Section 2(b) of the Rules of Court, the correct mode of appeal to the CA from such a judgment is by petition for review. An appeal by notice of appeal from an appellate judgment of the RTC is subject to dismissal under Rule 50, Section 2.