**Facts:**
– **July 2011:** Petitioner William Anghian Siy filed a Complaint for Recovery of Possession with Prayer for Replevin against Frankie Domanog Ong, Chris Centeno, John Co Chua, and Alvin Tomlin at the Regional Trial Court (RTC) of Quezon City.
– **Complaint:** Siy alleged ownership of a 2007 Range Rover (Plate No. ZMG 272) purchased from Alberto Lopez III in 2009. He entrusted the vehicle to Ong for sale, who failed to remit proceeds or return the vehicle. Ong transferred it to Chua, then to Tomlin, who attempted to process its transfer at the PNP-HPG.
– **July 29, 2011 Order:** The RTC issued a Writ of Replevin after Siy posted an Php8,000,000 bond. The subject vehicle was seized.
– **August 17, 2011:** Tomlin filed an Omnibus Motion to quash the writ, dismiss the complaint, and return the vehicle, claiming ownership and alleging procedural issues.
– **November 21, 2011:** RTC denied Tomlin’s motion. Tomlin’s M.R. was also denied.
– **CA Petition:** Tomlin filed for Certiorari with the Court of Appeals (CA-G.R. SP No. 124967).
– **October 9, 2012 Decision & February 19, 2013 Resolution:** The CA ruled for Tomlin, dismissing Civil Case No. Q-11-69644 for lack of jurisdiction due to incorrect docket fees and improper writ service.
**Issues:**
1. **Jurisdiction:** Whether the RTC had jurisdiction despite the allegation of incorrect payment of docket fees.
2. **Compliance with Rule 60:** Whether Siy sufficiently alleged all material facts required under Rule 60 of the Rules of Court in his Complaint and Affidavit of Merit.
3. **Writ Implementation:** Validity of the sheriff’s procedure in executing the writ of replevin by serving it after seizing the vehicle.
**Court’s Decision:**
– **Issue 1 (Jurisdiction):** The Supreme Court affirmed that RTC lacked jurisdiction due to Siy’s intentional undervaluation of the vehicle to reduce docket fees, thus amounting to fraud.
– **Issue 2 (Rule 60 Compliance):** Siy did not sufficiently allege required facts under Section 2, Rule 60, specifically failing to provide adequate vehicle value and conditions regarding distraint, seizure, or custodia legis.
– **Issue 3 (Writ Implementation):** Serving the writ post-seizure was improper. Rule 60 mandates prior service unless immediate seizure is imperative, which was not demonstrated here.
**Doctrine:**
– **Jurisdiction & Docket Fees:** Proper jurisdiction requires accurate payment of docket fees. Intentional misdeclaration to evade fees constitutes jurisdictional defect.
– **Replevin Requirements (Rule 60):** Detailed compliance with Rule 60 is imperative, including ownership, wrongful detention statement, seizure status, and true market value.
– **Proper Service of Writs:** Writs should generally be served before seizure unless specific proofs justify immediate seizure.
**Class Notes:**
– **Replevin (Rule 60):**
– *Affidavit Requirements*: Ownership or right to possession, wrongful detention, non-custodia legis status, market value (Sec 2, Rule 60).
– *Bond*: Double the value posited for the property.
– **Jurisdictional Requirement:**
– Accurate payment of docket fees—Sun Insurance Office, Ltd. v. Asuncion.
– **Procedural Regularity:**
– Correct service procedures—failure to follow mandates like prior service can invalidate proceedings.
**Historical Background:**
– **Vehicle Ownership Issues:** The case highlights common practices in the Philippines involving multiple sales transactions of vehicles without proper registration updates, often leading to legal disputes. It reflects on agency law, and the significance of due procedural diligence in replevin cases particularly focusing on ownership and right of possession.
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