G.R. No. 221815 November 29, 2017
GLYNNA FORONDA-CRYSTAL, Petitioner vs. ANIANA LAWAS SON, Respondent

FACTS

Respondent Aniana Lawas Son filed an action for reconveyance and damages against petitioner Glynna Foronda-Crystal before the Regional Trial Court (RTC) of Mandaue City. She claimed ownership of a parcel of land in Compostela, Cebu, which she allegedly purchased in 1986, asserting that the Free Patent and Original Certificate of Title (OCT) issued to petitioner’s father, Eddie Foronda, were erroneous. The petitioner moved to dismiss the case, arguing, among other grounds, that the RTC lacked jurisdiction because the property’s assessed value per its tax declaration was only ₱2,830.00, placing it within the exclusive original jurisdiction of the Municipal Circuit Trial Court.
The RTC initially dismissed the case for lack of jurisdiction but later reconsidered. It ruled that jurisdiction was properly vested in the RTC because the complaint alleged the property’s value was ₱200,000.00 (the purchase price), and the court took judicial notice that the BIR zonal valuation for the area likely exceeded ₱20,000.00. The RTC subsequently ruled in favor of the respondent, ordering the cancellation of the OCT and the issuance of a new title in her name. The Court of Appeals affirmed this decision.

ISSUE

Whether the Regional Trial Court had jurisdiction over the action for reconveyance.

RULING

The Supreme Court ruled that the RTC had no jurisdiction; thus, all proceedings and the resulting judgment were null and void. Jurisdiction over actions involving title to or possession of real property is determined by the assessed value of the property at the time of the filing of the complaint, not by its alleged market value or purchase price. The assessed value is the value declared for taxation purposes, as appearing in the tax declaration.
Here, the tax declaration presented by the respondent herself stated the assessed value was only ₱2,830.00. Under Batas Pambansa Blg. 129, as amended, this amount is unequivocally within the exclusive original jurisdiction of the Municipal Circuit Trial Court. The RTC’s reliance on the ₱200,000.00 purchase price alleged in the complaint and its judicial notice of BIR zonal valuations was a grave error. The law is clear that the tax declaration’s assessed value is the controlling factor for jurisdictional purposes. Since the RTC acted without jurisdiction, its decision and that of the CA affirming it are void. The case was remanded for dismissal without prejudice to refiling in the proper court.