NOTE
Recent Developments
Expanded jurisdiction of MTC; Republic Act No. 11576
Published 8 November 2021, The Daily Tribune
Republished by triplewdotdivinalawdotcom
In an effort to declog the dockets of trial courts, specifically second-level trial courts or the Regional Trial Courts (RTC) in the country, President Rodrigo Duterte signed into law Republic Act (RA) 11576, which expanded the jurisdiction of the first-level trial courts, namely the Metropolitan Trial Courts, Municipal Trial Courts in Cities, Municipal Trial Courts and Municipal Circuit Trial Courts (collectively referred to as MTC).
In passing the law, the legislature found that court congestion was mainly seen in the RTC where there were a higher number of pending cases as compared to the first-level trial courts. Thus, the government saw that expanding the jurisdictional threshold amount of the MTC can help in decongesting the court’s dockets and further alleviate the problem of delay in disposition of cases.
RA 11576 amends the 40-year-old law, Batas Pambansa (BP) 129, or the Judiciary Reorganization Act of 1980, by adjusting the threshold values for civil cases under the jurisdiction of the MTC.
According to the Supreme Court (SC), the last time the jurisdictional amounts of trial courts nationwide were adjusted was in 2004, when the amount in Sec. 33(1) of BP 129 for first-level trial courts outside of Metro Manila was increased to P300,000. Since then, no further amendment to the jurisdictional amounts of the first-level trial courts has been made.
With the passage of RA 11576, the SC affirmed that “the jurisdictional amounts of the trial courts have now been adjusted to levels which are more suitable to the current economic conditions and property valuation in the country.”
Actions involving title to, or possession of real property, or any interest thereinThe newly-signed law increased the jurisdictional amount cognizable by the RTC in all civil actions which involve the title to, or possession of, real property, or any interest therein from the previous amount of P20,000 (or P50,000 in Metro Manila) to P400,000.
Note, however, that the law retains the original jurisdiction over cases for forcible entry into and unlawful detainer of lands and buildings with the MTC.
Admiralty and maritimeRA 11576 also increased the jurisdictional amount cognizable by the RTC in all actions in admiralty and maritime jurisdiction to P2,000,000 from the previous amount of P300,000 (P400,000 in Metro Manila).
Probate matters, testate and intestateWith respect to all matters of probate, both testate and intestate, the law also increased the jurisdictional amount cognizable by the RTC to P2,000,000, from the previous amount of P300,000 (P400,000 in Metro Manila).
Other civil casesFinally, RA 11576 increased the jurisdictional amount cognizable by the RTC in all other cases in which the demand, exclusive of interest, damages of whatever kind, attorney’s fees, litigation expenses and costs or the value of the property in controversy to P2,000,000 from the previous amount of P100,000.
SC’s authority to adjust the jurisdictional amountsThe new law also delegates to SC the authority to adjust the jurisdictional amount for first- and second-level courts to: (1) reflect the extraordinary supervening inflation and deflation of currency; (2) reflect change in the land valuation; or (3) maintain the proportion of caseload between first- and second-level courts.
The law, however, provides that the delegated authority to the SC is without prejudice on the part of Congress to adjust the amounts when the circumstances so warrant.
RA 11576, which was signed last 30 July and took effect last 21 August 2021, is prospective in nature and shall only apply to all civil cases filed in the first- and second-level courts from the date of effectivity thereof.
The law aims to not only declog the dockets of second-level courts but also to expedite the adjudication of pending and incoming cases, which in turn would lead to a better administration of justice.
RE: Actions involving title to, or possession of real property, or any interest therein
The Court's Ruling
The instant Petition is unmeritorious. Petitioner Elmer's Complaint involves the title to, possession of, and interest in real property, i.e., the subject property, which indisputably has an assessed value of below P20,000.00.
Hence, the RTC had no jurisdiction to hear the case.
Jurisdiction is defined as the power and authority of a court to hear, try, and decide a case. For the court or an adjudicative body to have the authority to dispose of the case on the merits, it must acquire, among others, jurisdiction over the subject matter. It is axiomatic that jurisdiction over the subject matter is the power to hear and determine the general class to which the proceedings in question belong; it is conferred by law and not by the consent or acquiescence of any or all of the parties or by the erroneous belief of the court that it exists.19
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According to BP 129, as amended by Republic Act No. (RA) 7691, the Metropolitan Trial Courts, Municipal Trial Courts, and Municipal Circuit Trial Courts have 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 P20,000.00 or, in civil actions in Metro Manila, where such assessed value does not exceed P50,000.00.20 On the other hand, in all civil actions in which the subject of the litigation is incapable of pecuniary estimation, the Regional Trial Courts shall have exclusive original jurisdiction.21
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It is the bone of contention of petitioner Elmer that the Complaint that he filed before the RTC is incapable of pecuniary estimation as the principal relief that he is seeking is the cancellation of certain documents, i.e., the Affidavit of Adjudication, Tax Declaration No. 5289, and OCT No. P-14452.
The Court is not convinced.
Jurisprudence has held that an action "involving title to real property" means that the plaintiffs' cause of action is based on a claim that he owns such property or that he has the legal rights to have exclusive control, possession, enjoyment, or disposition of the same.22
In connection with the foregoing, it is a hornbook doctrine that a court's jurisdiction over the subject matter of a particular action is determined by the plaintiffs' allegations in the complaint and the principal relief he seeks in the light of the law that apportions the jurisdiction of courts.23
Related
Suggested answer in Political Law & International Law Read here
Hence, the Court has held that even if the action is supposedly one for annulment of a deed, the nature of an action is not determined by what is stated in the caption of the complaint but by the allegations of the complaint and the reliefs prayed for. Where the ultimate objective of the plaintiffs is to obtain title to real property, it should be filed in the proper court having jurisdiction over the assessed value of the property subject thereof.24
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Applying the foregoing in the instant case, the Complaint itself unequivocally states that petitioner Elmer, by filing the said Complaint, seeks to compel respondents Santiago and Charlie "to respect the right of ownership and possession over the land in question by the heirs of [Dominga.]"25
In fact, in the instant Petition, petitioner Elmer himself declares that "the narration on the complaint would show that the petitioner was only establishing his rightful ownership over the subject property."26
Simply stated, at the heart of petitioner Elmer's Complaint is his assertion of the right of ownership and possession over the subject property as against respondents Santiago and Charlie. Primarily, petitioner Elmer seeks to establish and confirm his supposed "rightful ownership" over the subject property.
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Further, the Complaint asks that the RTC order respondent Santiago "to reconvey the above-described property of the deceased [Dominga] to her surviving heirs and to demolish his house and any other structures erected therein x x x [and that respondent Charlie] demolish his house which has been constructed in bad faith within a portion of the residential area of the land in question and any other structures erected therein."27
Hence, more than asking for the nullification of documents, it is crystal clear that petitioner Elmer asserts his alleged right of possession over the subject property by seeking the reconveyance of the subject property.
According to jurisprudence, "[i]n a number of cases, [the Court has] held that actions for reconveyance of or for cancellation of title to or to quiet title over real property are actions that fall under the classification of cases that involve [']title to, or possession of, real property, or any interest therein.[']"28 Hence, the instant case is clearly one involving title to, possession of, and interest in real property.
RELATED
Nonetheless, petitioner Elmer makes the argument that "the main objective of the suit is the cancellation of the respondents' title (OCT No. P-14452)"29 because the other reliefs stated in the Complaint, which include compelling respondents Santiago and Charlie to recognize and respect the alleged right of ownership of petitioner Elmer, are merely incidental and largely depend on the result of the main action for cancellation of the subject OCT.30
Petitioner Elmer's argument is erroneous. He had it the other way around. Proverbially, this argument puts the cart before the horse.
In Heirs of Generoso Sebe v. Heirs of Veronico Sevilla,31 which substantially share a similar set of facts with the instant case, the petitioners therein filed an action for annulment of documents, reconveyance and recovery of possession with damages involving real property with an assessed value of less than P20,000.00 before the RTC. The said action was dismissed due to lack of jurisdiction.
Completely analogous to the main argument of petitioner Elmer, the petitioners in the aforesaid case similarly argued that "their action is, first, for the declaration of nullity of the documents of conveyance that defendant Sevilla tricked them into signing and, second, for the reconveyance of the certificate of title for the two lots that Sevilla succeeded in getting. The subject of their action is, they conclude, incapable of pecuniary estimation."32
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In upholding the RTC's dismissal of the action due to lack of jurisdiction, the Court therein explained that "title" is different from a "certificate of title" which is the document of ownership under the Torrens system of registration issued by the government through the Register of Deeds. While "title" gives the owner the right to demand or be issued a "certificate of title," the holder of a certificate of title does not necessarily possess valid title to the real property. The issuance of a certificate of title does not give the owner any better title than what he actually has in law. Therefore, a plaintiffs action for cancellation or nullification of a certificate of title may only be a necessary consequence of establishing that the defendant lacks title to real property.33 Hence, the Court therein held that:
The present action is, therefore, not about the declaration of the nullity of the documents or the reconveyance to the Sebes of the certificates of title covering the two lots. These would merely follow after the trial court shall have first resolved the issue of which between the contending parties is the lawful owner of such lots, the one also entitled to their possession, x x x34 (Underscoring supplied)
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Applying the foregoing in the instant case, the primary relief being sought by petitioner Elmer is really the establishment and confirmation of his right of ownership and possession over the subject property as against respondents Santiago and Charlie, considering that the cancellation of the subject OCT would merely follow and would merely be a consequence of the determination of petitioner Elmer's title over the subject property.
Hence, as the subject matter of petitioner Elmer's Complaint involves title to, possession of, and interest in real property which indisputably has an assessed value of below P20,000.00, the CA was correct in finding that the RTC had no jurisdiction to hear, try and decide the case.
WHEREFORE, the instant petition is DENIED. The assailed Decision dated November 28, 2014 and Resolution dated March 23, 2015 rendered by the Court of Appeals in CA-G.R. SP No. 133658 are AFFIRMED.
SO ORDERED.
Carpio, Acting C.J.,* (Chairperson, Caguioa, J. Reyes, Jr., Hernando,** and Zalameda, JJ., concur.
[ G.R. No. 217755, September 18, 2019 ]
ELMER MONTERO, PETITIONER, VS. SANTIAGO MONTERO, JR. AND CHARLIE MONTERO, RESPONDENTS.
Read the full text here
Citations
19 Foronda-Crystal v. Son, G.R. No. 221815, November 29, 2017, 847 SCRA 280, 288-289.
20 Sec. 5.
21 BP 129, Sec. 1.
22 Heirs of Generoso Sebe v. Heirs of Veronica Sevilla, 618 Phil. 395, 407 (2009).
23 Id. at 403.
24 Spouses Huguete v. Spouses Embudo, 453 Phil. 170, 176-177 (2003).
25 Rollo, p. 68; emphasis supplied.
26 Id. at 21; emphasis and italics supplied.
27 Id. at 67-68.
28 Heirs of Valariano Concha, Sr. v. Sps. Lumocso, 564 Phil. 580, 596 (2007); emphasis and underscoring supplied.
29 Rollo, p. 21.
30 Id.
31 Supra note 22.
32 Id. at 406-407.
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