GR 204314; (April, 2016) (Digest)
G.R. No. 204314. April 6, 2016.
HEIRS OF DANILO ARRIENDA, ROSA G. ARRIENDA, MA. CHARINA ROSE ARRIENDA-ROMANO, MA. CARMELLIE ARRIENDA-MARA, DANILO MARIA ALVIN G. ARRIENDA, JR., and JESUS FRANCIS DOMINIC G. ARRIENDA, Petitioners, vs. ROSARIO KALAW, Respondent.
FACTS
Danilo Arrienda filed an unlawful detainer complaint with the Municipal Trial Court (MTC) of Calauan, Laguna, against Rosario Kalaw and others. Arrienda alleged he was the owner of a parcel of land and that the defendants were occupying a portion of it. He claimed he allowed them to stay on the condition they would vacate upon his notice, which he gave in November 2000, but they refused to leave. Kalaw, in her Answer, contended the MTC lacked jurisdiction as the main issue involved ownership and tenancy, claiming she was a tenant and later an owner by donation. The MTC dismissed the complaint for lack of jurisdiction, ruling that the question of possession could not be determined without settling ownership. Arrienda appealed to the Regional Trial Court (RTC). The RTC took cognizance of the case, conducted a trial, and ruled in favor of Arrienda, ordering the defendants to vacate and pay rentals and attorney’s fees. Kalaw appealed to the Court of Appeals (CA). The CA reversed the RTC Decision, holding that the RTC did not acquire jurisdiction because Arrienda failed to allege the assessed value of the property in his complaint, rendering the RTC Decision null and void. The heirs of Arrienda (petitioners) filed the instant petition.
ISSUE
Whether the Regional Trial Court (RTC) had jurisdiction over Arrienda’s appeal from the MTC Decision, notwithstanding the failure to allege the assessed value of the subject property in the complaint.
RULING
Yes. The Supreme Court granted the petition, set aside the CA Decision and Resolution, and reinstated the RTC Decision. The Court ruled that the RTC was exercising its appellate jurisdiction under Section 22 of Batas Pambansa Blg. 129, as amended, when it took cognizance of the appeal from the MTC. The requirement to allege the assessed value of the property to determine jurisdiction applies only when courts are exercising original jurisdiction, not appellate jurisdiction. The RTC’s appellate jurisdiction over cases decided by first-level courts is not limited by the amount or value involved. Therefore, the assessed value was immaterial for the RTC’s appellate jurisdiction, and the CA erred in nullifying the RTC Decision for lack of jurisdiction.