Bangko Sentral v. Legaspi
REITERATIONFacts
1. The Antecedents: The Bangko Sentral ng Pilipinas (BSP) filed a complaint for annulment of title, revocation of certificate, and damages against several individuals, including respondent Feliciano P. Legaspi, then Mayor of Norzagaray, Bulacan. The core of the dispute involved a property allegedly covered by OCT No. P858/Free Patent No. 257917, which the BSP sought to protect from the construction of a dumpsite or landfill. 2. Procedural History: The Regional Trial Court (RTC) initially issued a preliminary injunction enjoining the construction of the dumpsite. Respondent Legaspi moved to dismiss the complaint, raising issues of jurisdiction over the person of the BSP and the subject matter, citing unauthorized suit and counsel. The RTC denied this motion. Respondent Legaspi then filed a motion for reconsideration, adding that the RTC lacked jurisdiction because the complaint failed to state the assessed value of the property. The RTC denied this motion as well. Aggrieved, respondent Legaspi filed a petition for certiorari with the Court of Appeals (CA). The CA granted the petition, setting aside the RTC orders and dismissing the BSP's complaint. 3. The Petition: The BSP filed a Petition for Review on Certiorari under Rule 45 of the Rules of Court, seeking to reverse the CA's decision. The BSP argued that the RTC had exclusive original jurisdiction because the assessed value of the property, as shown in an attached tax declaration, exceeded P20,000.00. Furthermore, the BSP contended that it was lawfully represented by private counsel, as authorized by the Monetary Board through specific resolutions, which empowered the BSP Governor or delegated officers to engage legal services, including private counsel, for legal proceedings.
Issue(s)
Whether the Regional Trial Court (RTC) has exclusive original jurisdiction over the subject matter of the case. Whether BSP lawfully engaged the services of its private counsel.
Ruling
The Supreme Court granted the Petition for Review on Certiorari, reversed and set aside the Decision and Resolution of the Court of Appeals, and affirmed the Orders of the Regional Trial Court. The case was remanded to the trial court for continuation of proceedings.
Ratio Decidendi
On the issue of jurisdiction: The Court held that the RTC has exclusive original jurisdiction over civil actions involving title to, possession of, or any interest in real property where the assessed value exceeds ₱20,000.00, as provided by Batas Pambansa Bilang 129, as amended by Republic Act No. 7691. While the complaint itself did not explicitly state the assessed value, an attached tax declaration (Annex "N") showed an assessed value of ₱215,320.00. The Court reiterated that annexes to a complaint are deemed part of it and should be considered in determining jurisdiction. Furthermore, the Court found that the RTC acted properly in taking judicial notice of the assessed value, especially considering the property's vast area of 4,838,736 square meters, making it absurd to assume an assessed value less than ₱20,000.00. The CA's reliance on Quinagoran v. Court of Appeals was deemed inapplicable as, in that case, no tax declaration or other document showing the assessed value was attached to the complaint. On the issue of legal representation: The Court ruled that the BSP Governor is authorized under Republic Act No. 7653 (New Central Bank Act) to represent the BSP, either personally or through counsel, including private counsel, as authorized by the Monetary Board. The Court noted that Monetary Board Resolution No. 865 dated June 17, 2004, delegated authority to the Director of the Asset Management Department to sign documents related to acquired assets, including those to be filed in court. Moreover, Monetary Board Resolution No. 900 dated July 18, 2008, explicitly approved the engagement of Ongkiko Kalaw Manhit and Acorda Law Offices (OKMA Law) as counsel for the BSP in the case. The Court found that the filing of the suit and the engagement of private counsel were duly authorized and that neither the Governor nor the Monetary Board disowned this authority. Therefore, the BSP was lawfully represented by its chosen counsel.
Main Doctrine
The RTC has exclusive original jurisdiction over real actions if the assessed value of the property exceeds ₱20,000.00. Annexes to a complaint, such as a tax declaration showing the assessed value, are considered part of the complaint for determining jurisdiction. The BSP Governor is authorized to represent the BSP, either personally or through counsel, including private counsel, as authorized by the Monetary Board.