GR 173351; (July, 2010) (Digest)
G.R. No. 173351 ; July 29, 2010
BF CITILAND CORPORATION, Petitioner, vs. MARILYN B. OTAKE, Respondent.
FACTS
Petitioner BF Citiland Corporation is the registered owner of a lot in Parañaque City with an assessed value of ₱48,000.00. Respondent Marilyn B. Otake purchased the adjoining lot but encroached upon petitioner’s property. Consequently, petitioner filed a complaint for accion publiciana (recovery of possession) before the Metropolitan Trial Court (MeTC) of Parañaque City. The MeTC ruled in favor of the petitioner, ordering the respondent to vacate the lot and pay compensation.
Respondent moved for reconsideration and later filed a motion to quash the writ of execution, arguing that the MeTC lacked jurisdiction over accion publiciana cases. The MeTC denied these motions, holding that under Section 33 of Batas Pambansa Blg. 129, as amended by Republic Act No. 7691 , it had exclusive original jurisdiction over civil actions involving title to or possession of real property where the assessed value does not exceed ₱50,000.00. The respondent then filed a petition for certiorari with the Regional Trial Court (RTC), which granted the petition and dismissed the case, ruling that accion publiciana fell under the exclusive original jurisdiction of the RTC regardless of the property’s value.
ISSUE
Whether the MeTC has jurisdiction over an accion publiciana case where the assessed value of the real property is ₱48,000.00, which is below the jurisdictional threshold.
RULING
Yes. The Supreme Court granted the petition and reinstated the MeTC Decision. The Court clarified that the amendment to BP 129 by RA 7691 expressly vested Metropolitan, Municipal, and Municipal Circuit Trial Courts with exclusive original jurisdiction over all civil actions involving title to or possession of real property, or any interest therein, where the assessed value does not exceed ₱50,000.00. This statutory grant includes accion publiciana, which is precisely an action for recovery of possession.
The RTC erred in relying on the outdated jurisprudential doctrine that accion publiciana was exclusively within RTC jurisdiction. That doctrine was superseded by the clear and unambiguous language of the amendatory law. The Court emphasized that jurisdiction is conferred by law, and RA 7691 deliberately expanded the jurisdiction of first-level courts. Since the assessed value of the subject lot was only ₱48,000.00, it was well within the MeTC’s jurisdictional limit. The action remained one for recovery of possession, and the assessed value of the improvements introduced by the respondent was irrelevant for jurisdictional purposes, as the complaint solely sought recovery of the land itself.