G.R. No. 202448 , December 13, 2017
Joseph O. Regalado, Petitioner, vs. Emma de la Rama Vda. de la Pena, Jesusa de la Pena, Johnny de la Pena, Johanna de la Pena, Jose de la Pena, Jessica de la Pena, and Jaime Antonio de la Pena, Respondents.

FACTS

The respondents are the registered owners of two parcels of land totaling 44 hectares in Murcia, Negros Occidental. They alleged that in 1994, the petitioner, Joseph Regalado, entered and took possession of these properties without their knowledge or consent, planting sugarcane without paying rent. After discovering the entry in the 1995-1996 crop year, respondents made verbal demands to vacate, which were unheeded. Following a failed barangay conciliation, they filed a Complaint for recovery of possession and damages with the Regional Trial Court (RTC) in March 1998.
In defense, petitioner claimed that respondents had executed waivers of their undivided shares in favor of co-respondent Jaime de la Pena, who subsequently waived his rights to the petitioner. He also filed a Motion to Dismiss, arguing the RTC lacked jurisdiction. He contended the action was for ejectment, involving recovery of physical possession filed within one year from barangay confrontation, and thus fell under the exclusive original jurisdiction of the Municipal Trial Court.

ISSUE

The primary issue is whether the Regional Trial Court had jurisdiction over the subject matter of the case.

RULING

The Supreme Court ruled that the RTC correctly exercised jurisdiction. The action filed by respondents was not an ejectment case but a plenary action for recovery of possession (accion publiciana). Jurisdiction over such an action is determined by the assessed value of the property. Forcible entry (accion interdictal) must be filed within one year from the date of unlawful deprivation. Here, respondents alleged deprivation of possession in 1994 but filed the case in 1998, well beyond the one-year period. The cause of action had therefore ripened into one for accion publiciana.
Under Batas Pambansa Blg. 129, as amended, the MTC has exclusive original jurisdiction over real property actions where the assessed value does not exceed P20,000 (or P50,000 in Metro Manila), while the RTC has jurisdiction where it exceeds these thresholds. The subject properties have a total area of 44 hectares. The Court affirmed the lower courts’ finding that it was safe to presume the assessed value exceeded P20,000, thereby vesting jurisdiction in the RTC. The petitioner’s failure to rebut this presumption with contrary evidence was fatal to his jurisdictional challenge. Consequently, the RTC and the Court of Appeals’ decisions were affirmed.