Plucena v. Balgos
REITERATIONFacts
The Antecedents: Petitioner Elizabeth Vidal-Plucena (Plucena) filed a Complaint for Recovery of Possession and Damages against respondents Hon. Flavian Balgos, Jr., Harvey Glenn Valencia, and Mrs. Franson Valencia. Plucena alleged she is the registered owner of a parcel of land covered by TCT No. T-19220, which she inherited from her parents and has been tilling since the 1980s. In 2013, she discovered that respondents had fenced a portion of her land and erected small concrete houses and pigpens without her consent. Upon inquiry, she learned that Mayor Balgos and Mrs. Franson claimed ownership of the occupied lot. A survey revealed that the respondents occupied approximately 60 square meters of the land, which Plucena claimed was unlawfully occupied. Plucena presented a tax declaration showing the entire property's assessed value at P34,160.00. Procedural History: Respondents questioned the RTC's jurisdiction, arguing that the assessed value of the 60-square meter portion, not the entire property, should determine jurisdiction. The RTC dismissed Plucena's complaint for lack of jurisdiction, holding that the basis for determining jurisdiction should be the portion sought to be recovered. Plucena's motion for reconsideration was denied. The Petition: Plucena assailed the RTC's dismissal, arguing that Batas Pambansa Blg. 129, as amended by Republic Act No. 7691, does not distinguish whether the title or interest in the property be in whole or in part, and that there is no separate tax declaration for the 60-square meter portion. She contended that the assessed value of the entire property should control.
Issue(s)
Did the RTC err in dismissing the Complaint for lack of jurisdiction over the subject matter; specifically, should the assessed value of the entire property or the specific portion sought to be recovered determine the jurisdiction of the court in an action involving title to or possession of real property? Did the petitioner violate the principle of hierarchy of courts by directly filing a petition for review on certiorari with the Supreme Court?
Ruling
The Petition is denied. The Orders of the Regional Trial Court, dated March 9, 2020, and July 20, 2020, are affirmed.
Ratio Decidendi
On the issue of jurisdiction and the basis for determining the assessed value: The Court held that the jurisdiction of a court in an action involving title to or possession of real property is determined by the assessed value of the specific portion of the property that is the subject of the litigation, not the assessed value of the entire property. The Court emphasized that Section 19(2) and Section 33(3) of Batas Pambansa Blg. 129 clearly refer to the "assessed value of the property involved" or "interest therein." In this case, the "property involved" or "interest therein" is the 60 square meters allegedly encroached and occupied by the respondents, which is the portion sought to be recovered. The assessed value of the entire property could not be the basis because the entire property was not involved in the case. The Court further noted that the party-plaintiff cannot be given the discretion to choose which assessed value to use, as this could lead to forum shopping. While Plucena argued that there was no separate tax declaration for the 60-square meter portion, the Court stated that this portion could be the subject of segregation and its approximate value determined through extant records, such as a tax declaration of adjacent lots if the subject lot was not declared. Plucena failed to do so. On the procedural issue of the hierarchy of courts: The Court reiterated that a petition for review on certiorari under Rule 45 is limited to questions of law, and factual questions are generally not proper subjects of such appeals. While the issue of which assessed value determines jurisdiction is a question of law, its resolution would involve a determination of facts, such as the valuation of the land, the size of the occupied portion, its location, and the valuation of that portion, which are all questions of fact. Furthermore, the Court stressed that direct recourse to the Supreme Court via a Rule 45 petition, when lower courts could have resolved the matter, runs afoul of the principle of hierarchy of courts. The Supreme Court is a court of last resort and must remain so to satisfactorily perform its constitutional functions. The Court found no recognized exceptions to this rule present in the case.
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 specific portion of the property that is the subject of the litigation, not the assessed value of the entire property, unless the entire property is involved.