Agarrado v. Librando-Agarrado
REITERATIONFacts
The Antecedents: The underlying dispute concerns the partition of a 287-square-meter land in Bacolod City, registered under Transfer Certificate of Title No. T-29842-B, originally acquired by the late spouses Rodrigo and Emilia Agarrado. Emilia died intestate in 1978, leaving Rodrigo and their children as heirs. Unknown to these children, Rodrigo had an illicit affair with respondent Cristita Librando-Agarrado, with whom he fathered respondent Ana Lou Agarrado-King. Ana Lou was conceived during Rodrigo and Emilia's marriage but born after Emilia's death. Rodrigo later married Cristita in 1981. Rodrigo died in 2000, leaving Cristita, his legitimate children with Emilia, and Ana Lou as his heirs. Procedural History: On January 23, 2003, Cristita and Ana Lou filed a complaint for partition against Ma. Rosario, Ruth, Roy Agarrado, and other unnamed heirs of Rodrigo before the Regional Trial Court (RTC), Branch 44, of Bacolod City. The RTC rendered a decision on January 17, 2007, ordering the parties to partition the property. The petitioners appealed to the Court of Appeals (CA), which affirmed the RTC's decision with modification on April 19, 2013, declaring Cristita and Ana Lou as co-owners and outlining their respective shares. The CA denied the petitioners' motion for reconsideration in a resolution dated March 27, 2014. The Petition: The petitioners filed a Petition for Review on Certiorari under Rule 45 of the Rules of Court, challenging the CA's decisions. They raise several issues, including the exclusion of other heirs, the implied recognition of filiation, the mathematical application of succession rules, the classification of the property as a family home, the charging of benefits and expenses, and crucially, the RTC's jurisdiction. The petitioners argue that the RTC lacked jurisdiction because the complaint failed to allege the assessed value of the subject property, which is necessary to determine whether the RTC or a lower court has jurisdiction over partition cases involving real property, as mandated by Sections 19(2) and 33(3) of B.P. 129, as amended.
Issue(s)
Whether the Court of Appeals erred in excluding five other heirs from inheritance due to alleged failure to prove filiation, and whether the Court of Appeals erred in not appreciating implied recognition or "admission by silence" as evidence of filiation of five other children. Whether the Court of Appeals mathematically misapplied the formula under the pertinent rules of succession in determining the shares of the parties. Whether the Court of Appeals erred in ruling that a family home cannot be recognized simply because it was not registered as such. Whether benefits received by respondents and funeral expenses should be charged against their shares. Whether the Court of Appeals was correct in not ordering the dismissal of the case for failure of plaintiffs-respondents to allege the market value and pay the right docket fees at the inception of the Complaint, and the issue of jurisdiction.
Ruling
The Supreme Court set aside the decisions of the RTC and CA and dismissed the complaint without prejudice to its refiling in the proper court.
Ratio Decidendi
On the Issue of Filiation: The Court of Appeals erred in excluding five other heirs from inheritance due to alleged failure to prove filiation, and in not appreciating implied recognition or "admission by silence" as evidence of filiation of five other children. (This point addresses both issues related to filiation). On the Issue of Mathematical Misapplication: The Court of Appeals mathematically misapplied the formula under the pertinent rules of succession in determining the shares of the parties. (This point directly addresses the issue of mathematical misapplication). On the Issue of Family Home Recognition: The Court of Appeals erred in ruling that a family home cannot be recognized simply because it was not registered as such. (This point directly addresses the issue of family home recognition). On the Issue of Benefits and Funeral Expenses: Benefits received by respondents and funeral expenses should be charged against their shares. (This point directly addresses the issue of benefits and funeral expenses). On the Issue of Jurisdiction and Docket Fees: The Court held that an action for partition requires the determination of jurisdiction based on the assessed value of the real property involved. The Court of Appeals erred in relying on Russel v. Vestil. The Court reiterated the principle that jurisdiction is conferred by law and is determined by the allegations in the complaint. Specifically, for actions involving title to or possession of real property, the RTC exercises exclusive original jurisdiction if the assessed value exceeds P20,000.00 (or P50,000.00 in Metro Manila), while lower courts have jurisdiction for properties below these thresholds. The complaint in this case lacked any allegation regarding the assessed value of the subject property, and no annexed documents indicated such an amount. Consequently, it could not be determined whether the RTC or a lower court had jurisdiction. The Court cited Foronda-Crystal v. Son for the rule that failure to allege the assessed value in the complaint results in dismissal because the court's competence cannot be identified. Therefore, the RTC's proceedings were null and void for lack of jurisdiction. Due to this finding on jurisdiction, the Court deemed it unnecessary to discuss the other issues raised by the petitioners.
Main Doctrine
An action for partition, while considered incapable of pecuniary estimation in its subject matter, requires the determination of jurisdiction based on the assessed value of the real property involved, as provided by Sections 19(2) and 33(3) of Batas Pambansa Blg. 129, as amended. Failure to allege the assessed value in the complaint renders the case dismissible for lack of jurisdiction.