Tacay v. Regional Trial Court of Tagum, Davao del Norte
REITERATIONFacts
The Antecedents: Three separate actions for recovery of possession (acciones publicianas) were filed by Godofredo Pineda against Antonia Noel (Civil Case No. 2209), Ponciano Panes (Civil Case No. 2210), and Maximo Tacay (Civil Case No. 2211). The complaints alleged that Pineda was the owner of a 790-square-meter parcel of land evidenced by TCT No. T-46560, that the defendants were occupying portions by mere tolerance, and that despite demands to vacate and pay rentals, they refused. The complaints prayed for declaration of ownership, delivery of possession, payment of P2,000.00 monthly rentals from February 1987, actual, moral, and nominal damages, and other just and equitable reliefs. A handwritten notation in the prayer indicated P5,000.00 for actual damages. Procedural History: Motions to dismiss were filed by the defendants, arguing that the trial court lacked jurisdiction due to non-compliance with Supreme Court Circular No. 7 (failure to specify damages) and the absence of the assessed value of the disputed lot. Judge Matas denied the motion in Civil Case No. 2210 but ordered the expunction of moral and nominal damages, and later struck out the P5,000.00 actual damages. Judge Fernandez denied the motions to dismiss in Civil Cases Nos. 2209 and 2211, declaring that the court had exclusive jurisdiction over the reivindicatoria action and ordering the expungement of unspecified damages. The Petition: Alleging grave abuse of discretion by both judges, the defendants filed a joint petition for certiorari, prohibition, and mandamus with the Supreme Court. They argued that the trial courts failed to acquire jurisdiction due to the non-specification of damages and that it was improper to merely expunge the damages claims while retaining the reivindicatoria cause of action. They prayed for the annulment of the orders and for the dismissal of the complaints.
Issue(s)
Whether the Regional Trial Court acquired jurisdiction over the accion publiciana cases despite the failure of the complaints to specify the amounts of actual, moral, and nominal damages. Whether the respondent judges committed grave abuse of discretion in denying the motions to dismiss and ordering the expungement of unspecified damages instead of dismissing the cases outright.
Ruling
The petition is DISMISSED. The Regional Trial Court correctly denied the motions to dismiss and ordered the expungement of unspecified damages, as the court's jurisdiction in accion publiciana is determined by the nature of the action and the payment of docket fees for the real property, not the amount of damages claimed. The respondent judges did not commit grave abuse of discretion.
Ratio Decidendi
On Issue 1: The Supreme Court held that the Regional Trial Court acquired jurisdiction over the accion publiciana cases. The Court explained that in real actions, such as an accion publiciana, the jurisdiction of the court is determined by the nature of the action and the value of the property involved, or the interest therein, and not by the amount of damages claimed. Batas Pambansa Bilang 129 grants Regional Trial Courts exclusive original jurisdiction over all civil actions involving the title to, or possession of, real property. The Court further clarified that while Circular No. 7 requires the specification of damages for the assessment of filing fees, the failure to do so in a real action does not divest the court of jurisdiction over the principal claim for possession. The proper procedure, as correctly done by the respondent judges, is to expunge the claims for damages or allow amendment within the prescriptive period, rather than dismissing the entire case. On Issue 2: The Supreme Court found no grave abuse of discretion on the part of the respondent judges. The judges correctly applied the law by recognizing that the cases were primarily actions for recovery of possession of real property, which fall under the exclusive original jurisdiction of the Regional Trial Courts, regardless of the value of the property. Their orders to expunge the claims for damages due to lack of specification, while maintaining the jurisdiction over the real action, were consistent with the Court's pronouncements on the matter. The petition's assertion that the cases should have been dismissed outright for failure to specify damages was deemed incorrect, as the nature of the action itself conferred jurisdiction upon the trial court.
Main Doctrine
The Supreme Court clarified that in actions for recovery of possession of real property (accion publiciana), the court's jurisdiction is determined by the nature of the action and the payment of the docket fees pertaining to the real property itself, irrespective of the value of the property or the amount of damages claimed. While Circular No. 7 requires specification of damages for fee assessment, the failure to specify amounts for actual, moral, or nominal damages in such real actions does not divest the Regional Trial Court of jurisdiction. Instead, the proper recourse is to either expunge the claims for damages or allow the amendment of the complaint to specify the amounts within the applicable prescriptive period, thereby curing the defect without dismissing the entire case.