G.R. No. 174346 , September 12, 2008
FERNANDA GEONZON VDA. DE BARRERA AND JOHNNY OCO, JR., Petitioners, versus HEIRS OF VICENTE LEGASPI, REPRESENTED BY PEDRO LEGASPI, Respondents.

FACTS

Respondents, the Heirs of Vicente Legaspi, filed a complaint for Reconveyance of Possession with Damages against petitioners Fernanda Geonzon Vda. de Barrera and Johnny Oco, Jr. before the Regional Trial Court (RTC) of Tangub City. They alleged that on October 1, 1996, petitioner Oco, accompanied by others, forcibly dispossessed them of a 0.9504-hectare irrigated farmland in Misamis Occidental, destroyed the crops, and took possession. Respondents asserted that their predecessors-in-interest had occupied and cultivated the land since 1935.
Petitioners, in their Answer, claimed ownership, asserting the land was part of a titled property originally under OCT No. P-447. They later raised a jurisdictional challenge in their Memorandum, arguing that the RTC lacked jurisdiction because the land’s assessed value was only P11,160 per Tax Declaration No. 7565, which falls below the jurisdictional threshold for the RTC over real actions after the amendments introduced by Republic Act No. 7691 .

ISSUE

The primary issue is whether the Regional Trial Court had jurisdiction over the subject matter of the complaint for reconveyance of possession, considering the assessed value of the property.

RULING

The Supreme Court granted the petition and set aside the decisions of the lower courts, declaring the RTC’s decision null and void for lack of jurisdiction. The Court held that jurisdiction over the subject matter is determined by the allegations in the complaint and the law at the time of its filing. The complaint, being a plenary action to recover possession (accion publiciana), is a real action. Under Section 33 of Batas Pambansa Blg. 129, as amended by R.A. No. 7691 , first-level courts (MTCs) have exclusive original jurisdiction over all civil actions involving title to or possession of real property where the assessed value does not exceed P20,000 (or P50,000 in Metro Manila).
The Court found that the assessed value of the property, as stated in the respondents’ own Tax Declaration No. 7565 and referenced in their complaint, was P11,160. This value is unequivocally below the P20,000 threshold. Consequently, exclusive original jurisdiction vested not in the RTC but in the proper Municipal Trial Court. The issue of jurisdiction may be raised at any stage of the proceedings and is not subject to estoppel. Since the RTC had no jurisdiction, all proceedings before it, including its decision, were void. This disposition made it unnecessary to resolve the ancillary issue regarding the role of ownership in a possessory action. The complaint was ordered dismissed.