JUAN V. SELGA, JR. AND CLARITA D. ENRIQUE, PLAINTIFFS-APPELLANTS, V. JUANITA DOCTOLERO, ADELAIDA PINTOR DEFENDANTS-APPELLEES.

Selga versus Doctolero

The Case

This is the case of Selga versus Doctolero. Juan Selga, Junior and Clarita Enrique sued Juanita Doctolero and Adelaida Pintor, asking the court to annul a deed of absolute sale and to reconvey to them a parcel of agricultural land covered by a certificate of land title. The complaint was captioned as one for annulment of sale and reconveyance with damages, but the trial court dismissed it for lack of jurisdiction, and the Supreme Court had to decide which court, the Regional Trial Court or the first level court, has jurisdiction. The case matters because it fixes the rule that in actions involving title to or possession of real property, including reconveyance, jurisdiction is measured by the assessed value of the property, and that value must be alleged in the complaint.

Procedural History

The plaintiffs filed their complaint with the Regional Trial Court of Agoo, La Union, Branch 32. On February 28, 2012, that court dismissed the complaint for lack of jurisdiction. It reasoned that although the complaint was captioned as an action incapable of pecuniary estimation, the caption does not determine the real nature of the action. Looking at the allegations, it found the case to be one of double sale and, ultimately, an accion reinvindicatoria, or a suit to recover ownership and possession, jurisdiction over which depends on the assessed value of the property. Since the complaint alleged no assessed value, and the evidence showed an assessed value of 7,100 pesos at the time of filing, which is below 20,000 pesos, the trial court held that the action fell within the exclusive original jurisdiction of the first level court, and declared all its proceedings null and void.

The plaintiffs appealed to the Supreme Court under Rule 41 of the Rules of Court, assigning as errors the dismissal for lack of jurisdiction and the trial court's characterization of their action as one for recovery of possession and ownership rather than an action to annul the deed of sale.

Facts

The subject is a parcel of agricultural land covered by Original Certificate of Title Number CLOA-5774. Juan Selga, Junior claims to have purchased the lot, and upon receiving an affidavit of adjudication with sale dated April 30, 2007, he sought to register the land in his name. He could not, because the Register of Deeds held all transactions in abeyance due to an adverse claim filed by the defendants, who asserted that they too were purchasers under a deed of absolute sale dated November 12, 2006.

Selga averred that he acquired the property during the lifetime of Mercedes Doctolero, relying on a clean certificate of land title bearing no annotation or claim. Clarita Enrique, for her part, claimed a vested right as a co-owner by succession, asserting that she was never informed of the sale between her mother Mercedes and the defendants. She recounted that in March 2007 she learned her mother wished to sell the land to Selga, and while in the United States she executed a quitclaim waiver of rights before the Philippine Consulate General in Los Angeles, dated March 12, 2007, out of love and affection for her mother. She later joined Selga as the real vendee.

The complaint prayed that the defendants' deed of absolute sale be declared null and void for not complying with the formalities and requirements of law, and that the property be reconveyed. The complaint did not allege the assessed value of the property. The tax declaration and property record form later adduced in evidence showed an assessed value of 7,100 pesos for the period when the complaint was filed in 2008.

Issues

• Whether or not the Regional Trial Court had jurisdiction over the complaint for annulment of sale and reconveyance.
• Whether or not the action is one incapable of pecuniary estimation, as the plaintiffs contend, or an accion reinvindicatoria governed by the assessed value of the property.

Applicable Provisions

Section 33, paragraph 3 of Republic Act 7691, amending the Judiciary Reorganization Act, provides:

Section 33. Jurisdiction of Metropolitan Trial Courts, Municipal Trial Courts and Municipal Circuit Trial Courts in Civil Cases. Metropolitan Trial Courts, Municipal Trial Courts and Municipal Circuit Trial Courts shall exercise: (3) Exclusive original jurisdiction in all civil actions which involve title to, or possession of, real property, or any interest therein where the assessed value of the property or interest therein does not exceed Twenty Thousand Pesos (P20,000.00) or, in civil actions in Metro Manila, where such assessed value does not exceed Fifty Thousand Pesos (P50,000.00) exclusive of interest, damages of whatever kind, attorney's fees, litigation expenses and costs: Provided, That in cases of land not declared for taxation purposes, the value of such property shall be determined by the assessed value of the adjacent lots.

This fixes the jurisdictional threshold of the first level courts and makes the assessed value the measure of jurisdiction over real property actions.

Section 19, paragraph 2 of the same law provides:

Section 19. Jurisdiction in civil cases. The Regional Trial Court shall exercise exclusive original jurisdiction: (2) In all civil actions, which involve the title to, or possession of, real property, or any interest therein, where the assessed value of the property involved exceeds Twenty Thousand Pesos (P20,000.00) or, for civil actions in Metro Manila, where such value exceeds Fifty Thousand Pesos (P50,000.00) except actions for forcible entry into and unlawful detainer of lands or buildings, original jurisdiction over which is conferred upon the Metropolitan Trial Courts, Municipal Trial Courts, and Municipal Circuit Trial Courts.

This is the mirror provision conferring jurisdiction on the Regional Trial Court only where the assessed value exceeds the threshold, so that the assessed value decides which court may act.

Ruling

On the first issue, the Court denied the appeal and held that the Regional Trial Court had no jurisdiction. It reiterated the hornbook principle that what determines jurisdiction is the nature of the action as pleaded in the complaint, and that the nature of an action is not determined by its caption but by the allegations and the reliefs prayed for.

On the second issue, the Court held that the allegations made out an accion reinvindicatoria, a remedy whereby a party claims ownership over a parcel of land and seeks recovery of its full possession. The complaint squarely put in issue the ownership of the disputed land, with Selga asserting ownership by virtue of the affidavit of adjudication with sale and Enrique by intestate succession, and the relief sought was the return of the land. The Court explained that with the amendments of Republic Act 7691, the test of the proper court no longer depends solely on the type of action but also on the assessed value of the property involved, and that the jurisdictional element is the assessed value. Actions for reconveyance or cancellation of title fall under the classification of cases involving title to, or possession of, real property, or any interest therein.

The Court stressed that the complaint must allege the assessed value of the property in order to determine which court has jurisdiction. Since the complaint contained no such allegation, it could not be shown that the Regional Trial Court had jurisdiction exclusive of the first level court. Even setting that infirmity aside, the tax declaration and property record form showing an assessed value of 7,100 pesos, well within the 20,000 peso limit, enjoyed the presumption of regularity and the trial court's factual findings deserved utmost respect. The Court added that when a court determines it has no jurisdiction over the subject matter, its only power is to dismiss the action. It also observed that the verification and certification attached to the complaint was defective for failure to comply with the notarial rules on competent evidence of identity, which would have warranted outright dismissal, since a pleading required to be verified but lacking proper verification is treated as an unsigned pleading.

Doctrine

Jurisdiction over an action is determined by the nature of the action as pleaded in the complaint, meaning its averments and the reliefs prayed for, and not by the caption of the complaint. An action claiming ownership of land and seeking its recovery is an accion reinvindicatoria, and actions for reconveyance or cancellation of title involve title to, or possession of, real property, or any interest therein. Under Republic Act 7691, jurisdiction over such actions depends on the assessed value of the property: the first level courts have exclusive original jurisdiction where the assessed value does not exceed 20,000 pesos, or 50,000 pesos in Metro Manila, while the Regional Trial Court has jurisdiction where the value exceeds those amounts. The complaint must therefore allege the assessed value of the property; absent such allegation, it cannot be determined which court has jurisdiction. When a court finds it has no jurisdiction over the subject matter, its only power is to dismiss the action.

Disposition

The Supreme Court affirmed the decision of the Regional Trial Court of Agoo, La Union, Branch 32, and dismissed the complaint for lack of jurisdiction, with no pronouncement as to costs.

Remember This

Memorize this line: in a real property action, the assessed value alleged in the complaint, not the caption, fixes jurisdiction. Examiners use this case to test the accion reinvindicatoria and the jurisdictional thresholds under Republic Act 7691, and to see whether you know that a complaint omitting the assessed value fails to establish the court's jurisdiction.