G.R. No. 187696 . June 15, 2016
FILOMENA CABLING, PETITIONER, VS. RODRIGO DANGCALAN, RESPONDENT.

FACTS

Petitioner Filomena Cabling filed a Complaint for recovery of possession and damages before the Municipal Circuit Trial Court (MCTC) against respondent Rodrigo Dangcalan, alleging that the perimeter fence he constructed encroached on approximately 13 square meters of her property, Lot No. 5056, with an assessed value of ₱2,100. Respondent denied encroachment and raised the affirmative defense of acquisitive prescription, claiming he built the fence in 1987 and that petitioner’s action, filed in 2001, was barred. The MCTC ruled in favor of petitioner, declaring respondent a builder in bad faith and ordering him to surrender possession and pay damages. On appeal, the Regional Trial Court (RTC) reversed the MCTC, holding that petitioner’s action had prescribed and that respondent was a builder in good faith.
Petitioner elevated the case to the Court of Appeals via a Petition for Review. The CA, however, did not rule on the substantive issues. Instead, it declared both the MCTC and RTC Decisions null and void for lack of jurisdiction. The appellate court held that the Complaint was an accion publiciana, a plenary action for recovery of possession, which it erroneously believed fell under the exclusive original jurisdiction of the RTC regardless of the property’s value.

ISSUE

Whether the Court of Appeals erred in nullifying the decisions of the MCTC and RTC on the ground that the MCTC lacked jurisdiction over the Complaint for recovery of possession.

RULING

Yes, the Court of Appeals erred. The Supreme Court granted the petition, reversed the CA Decision, and remanded the case to the CA for resolution on the merits. The legal logic is anchored on the correct application of jurisdictional rules governing actions for recovery of possession. The CA’s ruling was based on an outdated premise that all accion publiciana cases are within the exclusive original jurisdiction of the RTC. This is no longer good law.
Jurisdiction over such actions is determined by the assessed value of the property involved, pursuant to Republic Act No. 7691 , which expanded the jurisdiction of first-level courts. For properties outside Metro Manila, the MCTC has exclusive original jurisdiction over cases for recovery of possession where the assessed value does not exceed ₱20,000. Here, the subject property had an assessed value of only ₱2,100, which was explicitly alleged in the Complaint. Therefore, the MCTC correctly acquired jurisdiction over the case. The CA committed a reversible error by ignoring this clear statutory parameter and dismissing the case on a jurisdictional flaw that did not exist. Consequently, the CA should have proceeded to review the substantive issues raised by petitioner regarding prescription, laches, and good faith, rather than annulling the lower courts’ decisions.