Cabrera v. Clarin
REITERATIONFacts
The Antecedents: Petitioner Nestor Cabrera filed a complaint for accion publiciana with damages against respondents Arnel Clarin and wife, Milagros Barrios and husband, Aurora Serafin and husband, and Bonifacio Moreno and wife. Cabrera alleged that he is the lawful and registered owner of a 60,000 sq. m. agricultural land covered by TCT No. T-4439. He claimed that respondents encroached portions of his property, specifically Clarin with 63 sq. m., Barrios with 41 sq. m., Serafin with 30 sq. m., and Moreno with 11 sq. m., through fraud, strategy, and stealth. Despite oral and written demands to vacate, respondents refused, and conciliation at the barangay level failed. Procedural History: Respondents filed a Motion to Dismiss, arguing that the complaint failed to state the assessed value of the property for docket fee computation and that Cabrera did not submit a government-approved technical survey plan. They also questioned Cabrera's claim of ownership due to the property being registered in his and his deceased father's name, with no proof of partition. The RTC denied the motion, citing Aguilon v. Bohol, and later declared respondents in default for failure to file an Answer. Respondents filed an Omnibus Motion to set aside the default order, admit their Answer, and present evidence. The RTC ruled in favor of Cabrera, ordering respondents to vacate and pay attorney's fees and litigation expenses. The Court of Appeals (CA) reversed the RTC decision, dismissing the complaint for accion publiciana without prejudice for lack of jurisdiction, finding that the complaint failed to allege the assessed value of the property. The CA denied Cabrera's motion for reconsideration. The Petition: Cabrera filed a petition for review on certiorari before the Supreme Court, assailing the CA's decision and resolution. He argued that the CA erred in holding that the RTC lacked jurisdiction due to the absence of the assessed value in the complaint, contending that the doctrine of estoppel should apply. He also argued that the CA failed to consider the tax declaration annexed to his Appellee's Brief, which provided the assessed value.
Issue(s)
Whether the Court of Appeals committed a reversible error when it held that the Regional Trial Court has not acquired jurisdiction over the action due to the failure to allege the assessed value of the subject property in the complaint, and whether the doctrine of estoppel bars the respondents from raising this issue. Whether the Court of Appeals committed a reversible error when it failed to consider the tax declaration annexed to the Appellee's Brief which provided the assessed value of the property.
Ruling
The petition is denied. The Decision and Resolution of the Court of Appeals are affirmed. The Regional Trial Court's decision is declared null and void for lack of jurisdiction.
Ratio Decidendi
On the issue of jurisdiction and estoppel: The Supreme Court affirmed the CA's dismissal of the case for lack of jurisdiction. The Court reiterated that under Batas Pambansa Bilang 129, as amended by Republic Act No. 7691, the jurisdiction of the RTC in civil actions involving title to, or possession of, real property is determined by the assessed value of the property. The complaint must allege this assessed value to establish jurisdiction. In this case, Cabrera's complaint failed to state the assessed value of the disputed land, and no tax declaration was presented before the RTC to show its valuation. The Court cannot take judicial notice of the assessed or market value of land. While Cabrera argued for estoppel, the Court found that respondents are not estopped from assailing the RTC's jurisdiction because they raised the issue of lack of jurisdiction through a motion to dismiss even before filing their Answer. This differs from exceptional cases like Tijam v. Sibonghanoy where the issue was raised very late in the proceedings after the party had actively participated and sought affirmative reliefs. Here, respondents did not obtain affirmative relief from the trial court, and the issue was raised early. Therefore, the principle of estoppel by laches does not apply. On the failure to consider the tax declaration: The Supreme Court ruled that the CA did not err in not considering the tax declaration annexed to Cabrera's Appellee's Brief. The Court emphasized that evidence must be formally offered to be considered by the court, as mandated by Rule 132, Section 34 of the Rules of Court. A formal offer is necessary for the trial judge to know the purpose of the evidence and for the opposing party to object. While the rule on formal offer can be relaxed if the evidence is duly identified by testimony and incorporated in the records, Cabrera presented the tax declaration for the first time on appeal before the CA, without proof that it was presented or examined by the RTC. Therefore, it could not be considered by the appellate court. The Court also clarified that Section 5, Rule 10 of the Rules of Court, regarding amendments to conform to evidence, applies to proceedings before the trial court during the trial on the merits, not to belatedly filed documents before the appellate court. The belated presentation of a document proving the assessed value before the appellate court cannot cure the jurisdictional defect in the complaint.
Main Doctrine
The jurisdiction of a court in an action involving title to, or possession of, real property is determined by the assessed value of the property, and the failure to allege this value in the complaint, absent any exception, renders the proceedings void for lack of jurisdiction. Estoppel to question jurisdiction applies only under exceptional circumstances, particularly where a party actively participates in proceedings and seeks affirmative relief before raising the issue of jurisdiction, and not when the issue is raised early and the party has not obtained affirmative relief.