Liu v. Cruz
REITERATIONFacts
1. The Antecedents: Spouses Jimmy M. Liu and Emile L. Liu (petitioners) filed a complaint for recovery of real property (accion reivindicatoria), reconveyance, and to declare deeds of sale, power of attorney, and an affidavit of recovery null and void with damages against Alvin Cruz (private respondent). Petitioners alleged they are the registered owners of a parcel of land, but discovered their owner's duplicate copy of the title was missing. Upon reporting the loss and filing an affidavit of loss, they discovered annotations on the original title indicating a spurious Affidavit of Recovery and a spurious Special Power of Attorney, leading to an Absolute Deed of Sale between the private respondent and a third party, Tek Liong T. Jao. Petitioners claimed these documents were forgeries, that the notary public confirmed his signatures were forged, and that they received no proceeds from the alleged sale. They sought to nullify these documents, cancel the title in the private respondent's name, and recover ownership and possession of the property. 2. Procedural History: The case was filed with Branch 17 of the Regional Trial Court (RTC) in Davao City. The private respondent filed a motion to dismiss, arguing lack of jurisdiction due to the property's low assessed value. The RTC denied this motion. The private respondent then filed a petition for certiorari with the Court of Appeals (CA), assailing the RTC's denial of the motion to dismiss. The RTC subsequently declared the private respondent to have rested his case. The CA, in its Decision, ruled that the case involved title to real property and that jurisdiction depended on the assessed value, which was P19,840.00, placing it within the Municipal Trial Court's (MTC) jurisdiction. The CA denied the motion for reconsideration. The petitioners then filed the instant Petition for Certiorari with the Supreme Court. 3. The Petition: The petitioners filed a Petition for Certiorari under Rule 65 of the Rules of Court, seeking to set aside the Decision and Resolution of the Court of Appeals. They raised three main issues: (1) whether the CA gravely abused its discretion in failing to hold that the case was an action incapable of pecuniary estimation, thus vesting jurisdiction in the RTC; (2) whether the CA gravely abused its discretion in ordering the dismissal for lack of jurisdiction, remanding the case to the first-level court; and (3) whether the CA gravely abused its discretion in holding the assessed value of the property as determinative of jurisdiction. The Supreme Court, however, found the petition to be technically and substantially flawed, noting that the proper remedy should have been a petition for review on certiorari under Rule 45, and that the CA's ruling on jurisdiction based on the assessed value was correct.
Issue(s)
Whether or not the CA committed grave abuse of discretion amounting to lack or excess of jurisdiction in failing to hold that Civil Case No. 31,986-07 is an action which is not capable of pecuniary estimation, consequently vesting the RTC with jurisdiction. Whether or not the CA committed grave abuse of discretion amounting to lack or excess of jurisdiction in ordering the dismissal of Civil Case No. 31,986-07 for lack of jurisdiction, remanding the proceedings to the first level court. Whether or not the CA committed grave abuse of discretion amounting to lack or excess of jurisdiction in holding the assessed value of the Juan Luna Street property as determinative of the court's jurisdiction.
Ruling
The petition is dismissed for utter lack of merit. The Decision dated July 31, 2017 and the Resolution dated January 31, 2018 of the Court of Appeals in CA-G.R. SP No. 07413-MIN are affirmed.
Ratio Decidendi
On the Procedural Aspect (Petition for Certiorari vs. Petition for Review): The Court held that the petitioners' resort to a special civil action for certiorari under Rule 65 was a wrong remedy. Well-settled is the rule that appeals from judgments or final orders of the CA should be by a verified petition for review on certiorari under Rule 45. Certiorari under Rule 65 is proper only when there is no plain, speedy, and adequate remedy in the ordinary course of law. In this case, a petition for review under Rule 45 was available to the petitioners. The remedies of appeal and certiorari are mutually exclusive, and certiorari cannot be a substitute for a lost appeal, especially if the loss was due to the petitioner's own negligence or error in choosing the remedy. By filing a petition for certiorari, the period to file a petition for review under Rule 45 had already lapsed, rendering the assailed CA Decision and Resolution final. On the Substantive Aspect (Jurisdiction): The Court reiterated that actions for reconveyance, cancellation of title, or quieting of title over real property fall under cases involving "title to, or possession of, real property, or any interest therein." The distinction between actions incapable of pecuniary estimation and those involving title to property became crucial with the amendment introduced by R.A. No. 7691. This amendment expanded the exclusive original jurisdiction of the first-level courts to include civil actions involving title to, possession of, or any interest in real property where the assessed value does not exceed P20,000.00 (or P50,000.00 in Metro Manila). The CA correctly ruled that the MTC has jurisdiction because the complaint, while seeking to annul deeds and declare a title void, ultimately aimed to recover possession and ownership of the property, thus determining who between the parties has a better title. The averments in the complaint clearly indicated a claim of ownership and legal right to exclusive control, possession, enjoyment, or disposition of the property, which falls under actions involving title to real property, with the assessed value being the benchmark for jurisdiction.
Main Doctrine
A petition for certiorari under Rule 65 is not a substitute for a lost appeal under Rule 45. Furthermore, actions involving title to, or possession of, real property are classified based on the assessed value of the property to determine the jurisdiction of the courts, with cases involving an assessed value not exceeding P20,000.00 (or P50,000.00 in Metro Manila) falling under the exclusive original jurisdiction of the Metropolitan, Municipal, and Municipal Circuit Trial Courts.