G.R. No. 205998. April 24, 2017.
WILLIAM ANGIDAN SIY, Petitioner, vs. ALVIN TOMLIN, Respondent.

FACTS

Petitioner William Angidan Siy filed a Complaint for Recovery of Possession with Replevin against several parties, including respondent Alvin Tomlin, before the Regional Trial Court (RTC) of Quezon City. Siy alleged he was the owner of a Range Rover, having purchased it in 2009, and that he entrusted it to a co-defendant, Frankie Domanog Ong, for a prospective sale. Ong failed to return the vehicle or remit proceeds. Siy later discovered the vehicle had been transferred to Tomlin. The RTC granted Siy’s application for a writ of replevin upon posting a bond.
Tomlin filed an Omnibus Motion to quash the writ and dismiss the complaint. He argued he was the lawful registered owner per LTO documents dated March 7, 2011, and that Siy’s complaint was defective for failing to properly allege ownership, wrongful detention, and the vehicle’s actual market value to compute docket fees. Tomlin also contended the writ was improperly implemented against the PNP-HPG, which had custody of the vehicle. The RTC denied the motion, ruling the issues of ownership and sufficiency of allegations should be determined at trial and that Tomlin’s proper remedy was to post a counterbond.

ISSUE

Whether the Court of Appeals correctly granted Tomlin’s Petition for Certiorari, finding the RTC committed grave abuse of discretion in issuing the writ of replevin and not dismissing the complaint.

RULING

The Supreme Court reversed the Court of Appeals and reinstated the RTC orders. The Court held that the RTC did not commit grave abuse of discretion. A writ of replevin is a provisional remedy; its issuance is based on the applicant’s affidavit and bond, not a final determination of ownership. The allegations in Siy’s complaint and supporting affidavit substantially complied with Rule 60, Section 2 of the Rules of Court by describing his claim of ownership and the vehicle’s detention. Any perceived defects in the allegations, such as the specific cause of detention or the vehicle’s exact value, do not warrant the outright dismissal of the complaint at a preliminary stage but are matters for full litigation during trial.
The Court further ruled that the alleged undervaluation of the vehicle for docket fee purposes is not a jurisdictional defect that justifies dismissal. Under prevailing jurisprudence, a court acquires jurisdiction even upon partial payment of fees, and the outstanding balance constitutes a lien on the judgment. Tomlin’s claim of being the registered owner, supported by LTO documents, presents a factual dispute on ownership that must be resolved through a full-blown trial on the merits, not in a preliminary motion or a certiorari proceeding challenging the issuance of a provisional remedy. The RTC acted within its discretion in issuing the writ based on the prima facie case presented.