G.R. No. 234255, October 02, 2019
GENOVEVA G. GABRILLO, REP. HEREIN BY ATTORNEY-IN-FACT, MEDARDO G. CADIENTE, JR., PETITIONER, V. HEIRS OF OLIMPIO PASTOR REP. BY CRESENCIANA MANGUIRAN VDA. DE PASTOR, RESPONDENT.

FACTS

Petitioner Genoveva G. Gabrillo claimed ownership of a 9,000-square-meter parcel of land in Davao City, originally owned by spouses Olimpio and Cresenciana Pastor. The property was allegedly transferred to Ernesto A. Cadiente, Sr. via a 1967 Transfer of Rights and Sale of Improvements, and later conveyed to petitioner in 1991. Despite this, respondents (heirs of Olimpio Pastor) filed a free patent application, resulting in the issuance of Original Certificate of Title (OCT) No. P-14876 in their favor on December 29, 1997. Petitioner filed an action for Declaration of Trust and/or Declaration of Nullity of Title, Reconveyance, Damages, Attorney’s Fees and Injunction before the Regional Trial Court (RTC), alleging the market value of the property was P50,000.00 but failing to state its assessed value. The RTC dismissed the case for lack of jurisdiction due to the absence of the assessed value allegation and, alternatively, held the cause of action had prescribed. The Court of Appeals affirmed the dismissal. Petitioner argues that alleging market value suffices for jurisdiction, that respondents are estopped from challenging jurisdiction due to active participation, and that her action for reconveyance based on implied trust is imprescriptible as she is in possession.

ISSUE

Whether the Regional Trial Court acquired jurisdiction over petitioner’s action for reconveyance and annulment of title by the mere allegation of the market value, instead of the assessed value, of the subject property in the complaint.

RULING

No. The petition is denied. The RTC correctly dismissed the case for lack of jurisdiction. Jurisdiction over actions involving title to or possession of real property is determined by the assessed value of the property, not its market value, as explicitly provided under Sections 19(2) and 33(3) of Batas Pambansa Bilang 129, as amended by Republic Act No. 7691. Assessed value refers to the taxable value fixed by taxing authorities, while market value is the estimated price between a willing buyer and seller. Petitioner’s complaint only alleged the market value of P50,000.00 and failed to state the assessed value. Courts cannot take judicial notice of these values. The liberal application of the rule, which allows consideration of assessed value from annexed documents, does not apply here as no such document (e.g., tax declaration) was attached to the complaint. Consequently, the RTC could not determine if it had exclusive jurisdiction. The dismissal by the RTC and its affirmation by the Court of Appeals are upheld. The Court did not address the other issues on prescription and estoppel, as the lack of jurisdiction is dispositive.