Berbano v. Heirs of Tapulao
REITERATIONFacts
The Antecedents: Respondents, as heirs of Roman Tapulao, filed a Complaint for Recovery of Possession and Damages against petitioners. They claimed their father was the registered owner of a lot covered by OCT No. P-9331, and after his death, a relocation survey revealed petitioners occupied portions of the lot. Despite demands, petitioners refused to vacate. Procedural History: Petitioners, in their Answer, claimed ownership of a portion of the lot based on a cession from Felipe Peña, alleging that Roman Tapulao's title mistakenly included their portion. They asserted that Roman and Catalina Tapulao acknowledged this error via an Affidavit dated April 2, 1976. The case experienced multiple pre-trial resets, and petitioners failed to appear at the January 30, 2014 pre-trial, leading the trial court to grant respondents' motion to present evidence ex-parte. The RTC ruled in favor of respondents, declaring them rightful owners and ordering petitioners to vacate and pay damages. Petitioners moved for reconsideration, raising the issue of jurisdiction for the first time, arguing the assessed value of the disputed portion was below P20,000.00, thus falling under the Municipal Trial Courts' jurisdiction. The RTC denied the motion, citing the complaint's allegation of P22,070.00 as the assessed value of the entire lot. The Petition: On appeal, petitioners reiterated their lack of jurisdiction argument, claiming they were not notified of the pre-trial and that only the value of the disputed portion, not the entire lot, should determine jurisdiction. The Court of Appeals affirmed the RTC's decision, finding that respondents proved ownership and that the RTC acquired jurisdiction due to the assessed value exceeding P20,000.00. Petitioners now seek review by the Supreme Court, maintaining that the RTC lacked jurisdiction because the disputed portion's assessed value was only P8,111.72.
Issue(s)
Whether the Regional Trial Court (RTC) had jurisdiction over the subject matter of the case, considering the assessed value of the disputed portion of the property. Whether petitioners are estopped from questioning the RTC's jurisdiction after participating in the proceedings and seeking affirmative relief.
Ruling
The Supreme Court denied the petition and affirmed the decision of the Court of Appeals. The RTC properly exercised jurisdiction over the case.
Ratio Decidendi
On the issue of jurisdiction: The Court reiterated that jurisdiction over the subject matter is determined by the material allegations in the complaint and the relief sought, as conferred by law. Section 19 of Batas Pambansa Blg. 129, as amended by Republic Act No. 7691, grants RTCs exclusive original jurisdiction in civil actions involving title to or possession of real property where the assessed value exceeds P20,000.00. The complaint explicitly alleged that the subject lot had an assessed value of P22,070.00, which clearly falls within the RTC's jurisdiction. The petitioners' attempt to limit the jurisdictional assessment to the value of the specific portion they occupied was deemed irrelevant, as it did not alter the allegations made in the complaint by the plaintiffs. The Court emphasized that it is not for the defendants to redefine the allegations of the complaint, and the entire contiguous portion of the lot could be relevant to the remedies sought. Therefore, the RTC correctly assumed jurisdiction based on the stated assessed value in the complaint. On the issue of estoppel: The Court found that petitioners are estopped from questioning the RTC's jurisdiction. They actively participated in the proceedings before the trial court, filing an Answer and even seeking affirmative relief, including the dismissal of the case and the transfer of the lot's title to their names. It was only after an unfavorable judgment was rendered against them that they raised the issue of jurisdiction for the first time in their motion for reconsideration. Citing the case of Tijam, et al. v. Sibonghanoy, et al., the Court held that a party cannot invoke the jurisdiction of a court, seek affirmative relief, and then later repudiate or question that same jurisdiction. This principle of estoppel prevents parties from benefiting from their inconsistent stances regarding a court's authority.
Main Doctrine
Jurisdiction over the subject matter is determined by the material allegations of the complaint and the relief sought, not by the value of only a portion of the disputed property. A party who invokes the jurisdiction of a court and seeks affirmative relief cannot later question that same jurisdiction after an unfavorable ruling.