San Pedro v. Asdala
REITERATIONFacts
1. The Antecedents: The underlying dispute concerns a parcel of land in Batasan Hills, Quezon City, with an assessed value of P32,100.00. The heirs of spouses Apolonio and Valeriana Dionisio (private respondents) filed a complaint for Accion Reivindicatoria, Quieting of Title, and Damages against herein petitioners and the Wood Crest Residents Association, Inc. Private respondents alleged that the property was titled in their predecessors' names and that petitioners, in bad faith, claimed ownership of the land, preventing private respondents from possessing and using it. They further alleged that petitioners' title was spurious and sought to be declared the sole owners, to recover possession, and to claim damages and attorney's fees. 2. Procedural History: The private respondents initiated their action with the Metropolitan Trial Court (MeTC) of Quezon City, Branch 42. Petitioners moved to dismiss, arguing the MeTC lacked jurisdiction as the case involved a matter incapable of pecuniary estimation. The MeTC denied the motion, asserting its jurisdiction over actions involving title to or possession of real property of small value. Petitioners' motion for reconsideration was denied. They then filed a petition for certiorari with the Regional Trial Court (RTC) of Quezon City, Branch 87, which also dismissed their petition, affirming the MeTC's jurisdiction based on the assessed value of the property. Petitioners' subsequent motion for reconsideration with the RTC was denied. Subsequently, petitioners filed another petition for certiorari with the Court of Appeals (CA), again challenging the jurisdiction of the lower courts. The CA dismissed this petition outright, ruling that an appeal, not certiorari, was the proper remedy, and denied petitioners' motion for reconsideration. 3. The Petition: The petitioners are before the Supreme Court via a petition for certiorari under Rule 65 of the Rules of Court, seeking to reverse and set aside the Resolutions of the Court of Appeals. They contend that the CA, the RTC, and the MeTC all acted with grave abuse of discretion amounting to lack or excess of jurisdiction by not dismissing the Accion Reivindicatoria complaint for lack of jurisdiction. Specifically, they argue that the MeTC should not have taken cognizance of the case and that the RTC and CA erred in upholding the MeTC's jurisdiction. The Supreme Court, however, found the petition to be procedurally flawed, noting that the proper remedy from the CA's decision was a petition for review on certiorari under Rule 45, not a special civil action for certiorari under Rule 65, as an adequate remedy by appeal was available.
Issue(s)
Whether the Court of Appeals acted with grave abuse of discretion in dismissing the petition for certiorari. Whether the Metropolitan Trial Court has jurisdiction over the complaint for Accion Reivindicatoria.
Ruling
The petition is dismissed for utter lack of merit. The Resolutions of the Court of Appeals in CA-G.R. SP No. 78978, dated September 15, 2003 and June 1, 2004, are affirmed.
Ratio Decidendi
On the availability of certiorari: The Court reiterated the settled rule that appeals from judgments or final orders of the Court of Appeals should be filed via a petition for review on certiorari under Rule 45. A special civil action for certiorari under Rule 65 is proper only when there is no plain, speedy, and adequate remedy in the ordinary course of law. In this case, an appeal was available to the petitioners. Therefore, their resort to certiorari was a fatal procedural error, as remedies of appeal and certiorari are mutually exclusive. The Court of Appeals acted properly in dismissing the petition for certiorari on the ground that petitioners should have filed an appeal instead. On the jurisdiction of the Metropolitan Trial Court: The Court affirmed the rulings of the RTC and CA that the MeTC had jurisdiction over the private respondents' complaint for Accion Reivindicatoria. The Court cited Heirs of Valeriano S. Concha, Sr. v. Spouses Lumocso to explain that actions for reconveyance, cancellation of title, or quieting of title fall under cases involving "title to, or possession of, real property, or any interest therein." With the amendment introduced by R.A. No. 7691, exclusive original jurisdiction over such cases is vested in the first-level courts if the assessed value of the property does not exceed ₱20,000.00, or in Metro Manila, does not exceed ₱50,000.00. Since the assessed value of the subject property was ₱32,100.00, which is within the ₱50,000.00 limit for Metro Manila, the MeTC correctly exercised its jurisdiction.
Main Doctrine
A petition for certiorari under Rule 65 is not available when an appeal is the proper remedy, even if the ground is grave abuse of discretion. Furthermore, Metropolitan Trial Courts have exclusive original jurisdiction over actions involving title to or possession of real property where the assessed value does not exceed P50,000.00 in Metro Manila, as amended by Republic Act No. 7691.