Heirs of Fernando v. De Belen
REITERATIONFacts
The Antecedents: This case concerns a dispute over the possession of a parcel of land located in Baliuag, Bulacan, registered under Original Certificate of Title (OCT) No. RO-487 (997). The petitioners, heirs of the late Jose Fernando, claim ownership of the 124,994 square meter property, which they intended to partition as inheritance. Their efforts were obstructed by the respondent, Reynaldo De Belen, who allegedly intruded upon a portion of the land and conducted quarrying operations for many years without permission. The petitioners' attempts to resolve the matter through a demand letter and barangay conciliation proved unsuccessful, leading to the filing of a complaint for recovery of possession. Procedural History: The petitioners initiated a complaint for recovery of possession against Reynaldo De Belen before the Regional Trial Court (RTC), Branch 10 of Malolos City, Bulacan, in Civil Case No. 180-M-98. The respondent filed a Motion to Dismiss, which was denied by the RTC, ordering the petitioners to amend their complaint. An Amended Complaint was filed, followed by the respondent's Answer, which included claims of prescription, estoppel, and laches, and asserted his right of possession based on successive transfers of the property. After trial, the RTC rendered a decision in favor of the petitioners, declaring certain deeds of sale void and ordering the reconveyance of the property. The respondent appealed to the Court of Appeals, which set aside the RTC's decision for want of jurisdiction, finding that the RTC had not acquired jurisdiction due to the failure to allege the assessed value of the property. The Court of Appeals ordered the dismissal of the Amended Complaint. The Petition: The petitioners seek a reversal of the Court of Appeals' decision through a Petition for Review on Certiorari under Rule 45 of the Rules of Court. They argue that the Court of Appeals erred in holding that the RTC lacked jurisdiction. The petitioners contend that the respondent is estopped from questioning the RTC's jurisdiction due to his active participation in all stages of the proceedings before the trial court, including invoking its authority by filing an Answer and asserting his claim of ownership. Furthermore, they point out that the respondent's own Answer, which attached a deed of sale from 1979 for P60,000.00, indicated that the property's value at that time already exceeded the jurisdictional threshold for Regional Trial Courts under Republic Act 7691.
Issue(s)
Whether the Court of Appeals committed reversible error in holding that the RTC did not acquire jurisdiction for failure to allege the assessed value of the subject property. Whether the respondent is estopped from questioning the jurisdiction of the RTC after actively participating in the proceedings.
Ruling
The Court GRANTS the petition, REVERSES the assailed Decision of the Court of Appeals, and AFFIRMS the Regional Trial Court Decision. The records are remanded to the RTC for execution.
Ratio Decidendi
On the issue of jurisdiction and the assessed value of the property: The Court held that the Court of Appeals erred in ruling that the RTC lacked jurisdiction due to the failure to allege the assessed value of the property. While RA 7691 requires the assessed value to exceed ₱20,000.00 (or ₱50,000.00 in Metro Manila) for RTC jurisdiction over real property cases, the respondent's own Answer, which attached a Deed of Absolute Sale dated June 4, 1979, for ₱60,000.00, demonstrated that the property's value well exceeded the jurisdictional amount at the time of the respondent's purchase, which was nineteen years before the case was filed. This evidence, presented by the respondent himself, effectively established the RTC's jurisdiction over the subject matter. The Court emphasized that the allegations in the complaint and the relief sought determine the nature of the action and the court's jurisdiction, and in this instance, the respondent's own evidence confirmed the jurisdictional threshold was met. On the issue of estoppel from questioning jurisdiction: The Court ruled that the respondent is estopped from questioning the RTC's jurisdiction. The general rule that jurisdiction may be questioned at any stage is subject to the supervening principle of estoppel. In this case, the respondent actively participated in all stages of the proceedings before the RTC, including filing a Motion to Dismiss, an Answer, and participating in pre-trial and trial. He even invoked the RTC's authority by asserting his own claim of ownership over a portion of the property. Having benefited from the RTC's proceedings and only questioning its jurisdiction after an adverse judgment, the respondent is barred by estoppel from assailing the court's authority. The Court cited Tijam v. Sibonghanoy and Soliven v. Fastforms Philippines, Inc. to support the principle that active participation in the proceedings estops a party from later challenging jurisdiction.
Main Doctrine
A party who actively participates in all stages of the proceedings before a trial court, including invoking its authority by asking for affirmative relief, is estopped from challenging the trial court's jurisdiction, especially after an adverse judgment has been rendered. Furthermore, the assessed value of the property, as evidenced by a deed of sale executed nineteen years prior to the filing of the case, can establish that the Regional Trial Court has jurisdiction over cases involving title to or possession of real property.