G.R. No. 205966 , March 02, 2016
Bangko Sentral ng Pilipinas, Petitioner, vs. Feliciano P. Legaspi, Respondent.

FACTS

Petitioner Bangko Sentral ng Pilipinas (BSP) filed a Complaint for annulment of title, revocation of certificate and damages (with application for TRO/writ of preliminary injunction) against several defendants, including respondent Feliciano P. Legaspi, before the Regional Trial Court (RTC) of Malolos, Bulacan. The RTC issued an Order granting a preliminary injunction. Respondent Legaspi filed a Motion to Dismiss, alleging that the RTC did not acquire jurisdiction over the person of BSP because the suit was unauthorized and its counsel was not authorized to represent it. He also argued that the RTC lacked jurisdiction over the subject matter because the complaint, a real action, failed to allege the assessed value of the subject property. BSP opposed, arguing the complaint was filed pursuant to Monetary Board resolutions and that it could be represented by private counsel. The RTC denied the motion to dismiss, finding it had jurisdiction. The RTC also noted a Secretary’s Certificate attesting to Monetary Board Resolution No. 900, which approved engaging the services of the Ongkiko Kalaw Manhit and Acorda Law Offices (OKMA Law). Respondent filed a motion for reconsideration, reiterating the jurisdictional challenge regarding the assessed value. BSP opposed, claiming the property’s assessed value exceeded ₱20,000.00, as shown by a tax declaration attached to the complaint. The RTC denied the motion. Respondent elevated the case to the Court of Appeals (CA) via a petition for certiorari. The CA granted the petition, set aside the RTC Orders, and dismissed BSP’s complaint. BSP’s motion for reconsideration was denied. Hence, BSP filed the present Petition for Review on Certiorari before the Supreme Court.

ISSUE

1. Whether the Regional Trial Court had exclusive original jurisdiction over the subject matter of the complaint.
2. Whether BSP lawfully engaged the services of its private counsel.

RULING

The Supreme Court granted the petition, reversing the CA Decision and Resolution.
1. On Jurisdiction over the Subject Matter: The RTC had exclusive original jurisdiction. Under Batas Pambansa Bilang 129, as amended, the RTC has jurisdiction over civil actions involving title to or possession of real property where the assessed value exceeds Twenty Thousand Pesos (₱20,000.00). While the complaint on its face did not state the assessed value, a tax declaration (Annex “N”) attached to the complaint showed an assessed value of ₱215,320.00. Annexes to a complaint are deemed part of it and should be considered together with the complaint in determining sufficiency. Therefore, the RTC correctly took judicial notice of this assessed value from the public record attached to its files, confirming its jurisdiction.
2. On Authority of Counsel: BSP lawfully engaged its private counsel. Section 18 of Republic Act No. 7653 (The New Central Bank Act) authorizes the Governor of the BSP to represent the Bangko Sentral, either personally or through counsel, as may be authorized by the Monetary Board, in any legal proceedings. This power to represent may be delegated to other officers. The complaint was verified by Geraldine Alag, Director of Asset Management of the BSP, who stated she was authorized by Monetary Board Resolutions. Furthermore, a Secretary’s Certificate was presented attesting to Monetary Board Resolution No. 900, which approved the engagement of the OKMA Law firm. Therefore, the representation was lawful and authorized.