G.R. No. 165133 ; April 19, 2010
Spouses Joselina Alcantara and Antonio Alcantara, and Spouses Josefino Rubi and Annie Distor-Rubi, Petitioners, vs. Brigida L. Nido, as attorney-in-fact of Revelen N. Srivastava, Respondent.

FACTS

Respondent Brigida Nido, acting as administrator and attorney-in-fact for her daughter and lot owner Revelen Srivastava, filed a complaint for recovery of possession with damages against petitioners. The dispute originated from a 1984 oral agreement where petitioners agreed to purchase a 200-square meter portion of Revelen’s unregistered land. Petitioners paid a downpayment and subsequent installments totaling ₱17,500, constructed houses, and, with consent, occupied an additional area. They later defaulted on payments. The Regional Trial Court (RTC) declared the oral contract to sell void under Article 1874 of the Civil Code, which requires an agent’s authority for the sale of land to be in writing. The RTC ordered rescission, mutual restitution, and the payment of attorney’s fees.
Petitioners appealed to the Court of Appeals, which reversed the RTC. The appellate court held that the RTC lacked jurisdiction over the case. It determined the action was essentially one for unlawful detainer, and even if treated as an accion publiciana, the assessed value of the property (₱4,890) fell below the jurisdictional threshold for the RTC under the amended provisions of Batas Pambansa Blg. 129 by Republic Act No. 7691 . The Court of Appeals dismissed the complaint.

ISSUE

Whether the Court of Appeals correctly dismissed the complaint on the ground of lack of jurisdiction by the RTC.

RULING

The Supreme Court affirmed the Court of Appeals’ dismissal, upholding the lack of jurisdiction. The core legal logic rests on the mandatory nature of jurisdictional rules. At the time the complaint was filed in May 1994, Republic Act No. 7691 was already in effect. This law amended the jurisdiction of first-level courts, granting them exclusive original jurisdiction over actions involving title to or possession of real property where the assessed value does not exceed ₱20,000 (or ₱50,000 in Metro Manila). The complaint explicitly alleged the assessed value of the entire 1,939-square meter lot was only ₱4,890, a figure squarely within the exclusive jurisdiction of the Municipal Trial Court.
Jurisdiction is conferred by law and determined by the allegations in the complaint and the assessed value of the property at the time of filing. The RTC’s erroneous assumption of jurisdiction rendered all subsequent proceedings, including its decision on the merits, void. A judgment rendered by a court without jurisdiction is a nullity. The Supreme Court emphasized that the issue of jurisdiction can be raised at any stage and is not subject to the whims of the parties. Consequently, the RTC’s declaration on the voidness of the contract and its order for rescission were set aside. The proper remedy was dismissal of the complaint without prejudice to the filing of the appropriate action in the court of competent jurisdiction.