Supapo v. De Jesus
REITERATIONFacts
The Antecedents: Petitioners Esperanza Supapo and the late Romeo Supapo (Spouses Supapo) are the registered owners of a lot in Novaliches, Quezon City, covered by Transfer Certificate of Title (TCT) No. C-28441. In 1992, they discovered that respondents Spouses Roberto and Susan de Jesus and Macario Bernardo had built houses on the lot without permission. After failing to settle the dispute at the barangay level, the Spouses Supapo filed a criminal complaint for violation of Presidential Decree (PD) No. 772 (Anti-Squatting Law). The trial court convicted the respondents and ordered them to vacate. However, while the case was on appeal, Congress enacted Republic Act (RA) No. 8368, which repealed PD No. 772, leading to the dismissal of the criminal case. Procedural History: Following the dismissal of the criminal case, the Spouses Supapo moved for the execution of the respondents' civil liability (to vacate), but the Court of Appeals (CA) enjoined the execution, ruling that the repeal of the law extinguished both criminal and civil liabilities. The Spouses Supapo then filed a complaint for 'accion publiciana' (plenary action for recovery of possession) with the Metropolitan Trial Court (MeTC) of Caloocan City. The MeTC denied the respondents' motion to dismiss. On a petition for certiorari, the Regional Trial Court (RTC) reversed the MeTC, ordering the dismissal of the case for lack of jurisdiction and prescription. The CA affirmed the RTC's decision, holding that 'accion publiciana' falls under the RTC's jurisdiction and that the action had already prescribed. The Petition: The Spouses Supapo filed a petition for review on certiorari under Rule 45 before the Supreme Court. They argued that the MeTC has jurisdiction because the assessed value of the property (P39,980.00) is within the P50,000.00 threshold for Metro Manila. They further contended that their cause of action is imprescriptible because the property is registered under the Torrens system, and thus cannot be lost through prescription or laches.
Issue(s)
Whether the Metropolitan Trial Court (MeTC) properly acquired jurisdiction over the 'accion publiciana' based on the property's assessed value. Whether the cause of action for recovery of possession of registered land has prescribed. Whether the complaint for 'accion publiciana' is barred by 'res judicata' (prior judgment) due to the dismissal of the previous criminal case.
Ruling
The Supreme Court GRANTED the petition, REVERSED and SET ASIDE the Court of Appeals' decision, and held that the MeTC had jurisdiction and the action had not prescribed.
Ratio Decidendi
On Issue 1: The MeTC properly acquired jurisdiction. Under Batas Pansa Bilang (BP) 129, as amended by Republic Act (RA) No. 7691, jurisdiction over actions involving title to or possession of real property is determined by its assessed value. For civil actions in Metro Manila, the Metropolitan Trial Court (MeTC) has exclusive original jurisdiction if the assessed value of the property does not exceed Fifty Thousand Pesos (P50,000.00). In this case, the Spouses Supapo alleged and proved that the assessed value of the subject lot was P39,980.00, as shown in the tax declaration. Applying the doctrine in Quinagoran v. Court of Appeals, the Court clarified that the RTC no longer has plenary jurisdiction over all 'accion publiciana' cases; the value of the property is the controlling factor. Since the value fell below the statutory threshold, the MeTC was the correct forum. On Issue 2: The cause of action has not prescribed. The subject property is registered under the Torrens system, and Section 47 of Presidential Decree (PD) No. 1529 explicitly states that no title to registered land in derogation of the title of the registered owner shall be acquired by prescription or adverse possession. The Court has consistently held that the right of a Torrens title holder to eject any person illegally occupying their property is imprescriptible. Even if the respondents occupied the land for more than ten years, the lawful owners have a right to demand the return of their property at any time. The defense of laches is also unavailing because the Spouses Supapo actively pursued their rights through barangay conciliation, criminal prosecution, and the subsequent civil suit. Laches is evidentiary and was not proven by the respondents. On Issue 3: The action is not barred by 'res judicata'. 'Res judicata' requires identity of parties, subject matter, and causes of action between the first and second actions. In this case, there is no identity of parties because the criminal case was prosecuted in the name of the People of the Philippines, while the 'accion publiciana' was filed by the Spouses Supapo. There is no identity of subject matter or cause of action because the criminal case involved the prosecution of a crime under the Anti-Squatting Law, whereas the civil case is an action to recover possession based on proprietary interests. Furthermore, the concept of 'conclusiveness of judgment' does not apply because the issues in the two cases—criminal liability versus the better right of possession—are entirely different.
Main Doctrine
The jurisdiction of the first-level courts (MeTC, MTC, MCTC) and the Regional Trial Courts (RTC) over real actions, including 'accion publiciana', is determined by the assessed value of the property. In Metro Manila, if the assessed value is P50,000.00 or less, the MeTC has jurisdiction. Moreover, the right of a holder of a Torrens title to recover possession of the registered land is imprescriptible and cannot be barred by the possession of another, regardless of the duration of such possession, as provided under Section 47 of Presidential Decree (PD) No. 1529.