Arrienda v. Kalaw
REITERATIONFacts
The Antecedents: Danilo Arrienda filed an unlawful detainer case against Rosario Kalaw and others, alleging he owned an 11,635 sq. meter parcel of land and that the respondents occupied a portion thereof despite his ownership warranty that the property was free from occupants. He claimed he allowed them to stay on the condition they would vacate upon notice, which he gave in November 2000. The respondents failed to vacate. Procedural History: The Municipal Trial Court (MTC) dismissed the complaint for lack of jurisdiction, stating that the issue of ownership raised by the respondent could not be determined without settling ownership, thus divesting the MTC of jurisdiction. The MTC also dismissed the counterclaims. On appeal, the Regional Trial Court (RTC) took cognizance of the case, conducted a trial, and rendered a decision ordering the defendants to vacate the premises and pay damages and attorney's fees, finding Arrienda to be the owner. The Petition: The Court of Appeals (CA) reversed the RTC decision, ruling that the RTC lacked jurisdiction because Arrienda failed to allege the assessed value of the property in his complaint, rendering the RTC decision void. The heirs of Arrienda filed a petition for review on certiorari with the Supreme Court.
Issue(s)
Whether the Regional Trial Court (RTC) has jurisdiction over the appeal of an unlawful detainer case decided by the Municipal Trial Court (MTC). Whether the failure to allege the assessed value of the property in the complaint for unlawful detainer divests the RTC of jurisdiction when acting on appeal.
Ruling
The Supreme Court granted the petition, set aside the Court of Appeals' decision and resolution, and reinstated the Regional Trial Court's decision. The Court ruled that the RTC had jurisdiction over the appeal.
Ratio Decidendi
On the issue of RTC's jurisdiction over the appeal: The Court reiterated that under Batas Pambansa Blg. 129 (B.P. Blg. 129), as amended by Republic Act No. 7691 (RA 7691), RTCs possess both original and appellate jurisdictions. Section 22 of B.P. Blg. 129 explicitly grants RTCs appellate jurisdiction over all cases decided by Metropolitan Trial Courts, Municipal Trial Courts, and Municipal Circuit Trial Courts within their respective territorial jurisdictions. This appellate jurisdiction is exercised based on the entire record of the proceedings in the court of origin. Therefore, when the RTC took cognizance of Arrienda's appeal from the MTC's adverse decision in the ejectment suit, it was undeniably exercising its appellate jurisdiction as mandated by law. Consequently, its decision could not be annulled on the basis of lack of jurisdiction, as it possessed the authority to decide the appeal. On the issue of failure to allege assessed value: The Court clarified that the requirement to allege the assessed value of the property applies only when courts are exercising their original jurisdiction to determine which court has jurisdiction over a real action. In this case, the RTC was exercising its appellate jurisdiction, not its original jurisdiction. Section 22 of B.P. Blg. 129, which governs appellate jurisdiction, does not impose any limitation based on the amount or value of the subject property. Therefore, the assessed value of the disputed lot was immaterial for the RTC's exercise of its appellate jurisdiction. All cases decided by the MTC are generally appealable to the RTC, irrespective of the amount involved. The CA erred in nullifying the RTC decision for lack of jurisdiction on this ground.
Main Doctrine
The Regional Trial Court (RTC) exercises appellate jurisdiction over all cases decided by Municipal Trial Courts (MTCs), and this appellate jurisdiction is not limited by the assessed value of the property involved, unlike its original jurisdiction.