Descallar v. Heirs of Feria Guevara
REITERATIONFacts
The Antecedents: Belen A. Feria Guevara and Augustus Caesar A. Feria (plaintiffs) filed a Complaint for Accion Reivindicatoria and/or Reconveyance and Damages against Spouses Joel and Evangeline Descallar (defendants) involving a lot covered by TCT No. 10854. Spouses Descallar repeatedly failed to file an answer despite several extensions and orders from the Regional Trial Court (RTC). They were eventually declared in default. Procedural History: The RTC declared Spouses Descallar in default multiple times, denying their motions to lift the order of default. The Court of Appeals (CA) in a prior certiorari petition, ordered the inclusion of other co-heirs as indispensable parties and gave Spouses Descallar a non-extendible period to file an answer to the amended complaint. Despite this, Spouses Descallar again failed to file an answer and instead filed a motion to dismiss. The RTC denied their motion and declared them in default again. The RTC subsequently ruled in favor of the plaintiffs, declaring the heirs of Cristeta A. Feria as the rightful owners and ordering the transfer of the property. The CA modified the RTC decision by deleting the award of attorney's fees, affirming the declaration of default and the sufficiency of the evidence presented by the plaintiffs. Spouses Descallar's motion for reconsideration was denied. The Petition: Evangeline Descallar and her children (petitioners) filed a Petition for Review on Certiorari before the Supreme Court, assailing the CA's decision and resolution. They argued that the RTC lacked jurisdiction due to failure to allege the assessed value of the property and pay correct docket fees, that the cause of action had prescribed, that they were wrongly declared in default, and that the deed of sale was valid. The Supreme Court noted that the issue of jurisdiction was raised for the first time before it.
Issue(s)
Whether the RTC had jurisdiction over the Complaint. Whether petitioners were in default. Whether respondents sufficiently proved their case for reconveyance.
Ruling
The Supreme Court denied the petition for lack of merit. It affirmed the CA's decision, holding that the RTC had jurisdiction, petitioners were correctly declared in default, and respondents sufficiently proved their case for reconveyance.
Ratio Decidendi
On the issue of jurisdiction: The Court ruled that the RTC had jurisdiction. It clarified that jurisdiction is conferred by law and determined by the allegations in the complaint, not by the plaintiff's entitlement to recover. The Court found that the action for reconveyance based on implied trust was filed within the ten-year prescriptive period, reckoned from the issuance of the TCT in 1996. The Court also held that petitioners were estopped from raising the issue of lack of jurisdiction for failure to pay correct docket fees and allege assessed value, as this was raised for the first time on appeal after years of active participation in the proceedings. The Court emphasized that the issue of jurisdiction, while generally not lost by waiver or estoppel, can be barred by laches when raised belatedly and unjustly. On the issue of default: The Court affirmed the RTC's correct declaration of petitioners in default. It noted that Spouses Descallar repeatedly failed to file their answer despite numerous opportunities and extensions granted by the RTC. Even after the CA ordered them to file an answer to the amended complaint, they filed a motion to dismiss instead of complying. The Court reiterated that parties declared in default lose their right to be heard and present evidence, and their belatedly filed answer to the original complaint could not serve as an answer to the amended complaint due to its denial of admission by the RTC. On the sufficiency of the complaint for reconveyance: The Court found that respondents sufficiently proved their case by preponderance of evidence. Despite the CA finding Belen's testimony hearsay, it gave credence to other documentary evidence, including Cristeta's notarized letter to the Register of Deeds, letters to tenants, tenant acknowledgments of Cristeta's ownership, receipts issued by Cristeta, and the testimonies of Tayag and Dalumpines. These pieces of evidence established the existence of an implied trust and that Cristeta remained the beneficial owner of the property, thus entitling the heirs to reconveyance.
Main Doctrine
An action for reconveyance based on an implied trust prescribes in ten years, reckoned from the date of the issuance of the original certificate of title or TCT. Parties declared in default lose their right to be heard and present evidence, but may still appeal the judgment by default on specific grounds. Jurisdiction over the subject matter is conferred by law and determined by the allegations in the complaint, and the issue of jurisdiction may be deemed waived by estoppel if not timely raised.