GR 186366; (July, 2013) (Digest)
G.R. No. 186366; July 3, 2013
HEIRS OF JOSE FERNANDO, PETITIONERS, vs. REYNALDO DE BELEN, RESPONDENT.
FACTS
The petitioners, heirs of Jose Fernando, filed a complaint for recovery of possession before the Regional Trial Court (RTC) of Malolos, Bulacan against respondent Reynaldo De Belen. They alleged that while partitioning their inheritance, a parcel of land covered by OCT No. RO-487 (997), they discovered De Belen intruding upon and conducting quarrying operations on a portion of the property without their permission. Despite a demand letter and barangay conciliation, De Belen refused to vacate. The RTC ruled in favor of the petitioners, declaring null and void the series of deeds through which De Belen claimed ownership and ordering him to reconvey the property and pay rentals and attorney’s fees.
De Belen appealed to the Court of Appeals, which reversed the RTC decision. The CA held that the RTC lacked jurisdiction because the complaint failed to allege the assessed value of the property, which is essential for determining whether the case falls within the RTC’s exclusive original jurisdiction over real actions where the assessed value exceeds Twenty Thousand Pesos (₱20,000.00), or within the jurisdiction of first-level courts. The CA found this jurisdictional defect fatal, rendering the RTC’s judgment void.
ISSUE
Whether the Court of Appeals erred in dismissing the case on the ground that the Regional Trial Court lacked jurisdiction due to the petitioners’ failure to allege the assessed value of the subject property in their complaint.
RULING
Yes, the Court of Appeals erred. The Supreme Court reinstated the RTC decision, holding that the RTC validly acquired jurisdiction. While the complaint did not expressly state the assessed value, the jurisdictional requirement was substantially complied with. Jurisdiction is determined by the allegations in the complaint and the relief sought. The complaint sought recovery of a 9,838-square-meter portion of a larger 124,994-square-meter estate. More critically, the respondent’s own Answer and evidence provided the basis for jurisdiction. De Belen attached a deed of sale indicating he purchased the lot for ₱60,000.00 in 1979. The Court ruled that the purchase price in an authentic document can be used as a fair indicator of the property’s value for jurisdictional purposes, especially when the assessed value is not specified. Since ₱60,000.00 in 1979 far exceeded the ₱20,000.00 threshold under B.P. Blg. 129, the RTC clearly had exclusive original jurisdiction. The CA’s overly strict and technical application, which disregarded this evidence already part of the records, was incorrect. The RTC’s acquisition and exercise of jurisdiction were thus proper.