39 Heirs of Sps Ramiro Vs Bacaron

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Manzano, Dawn Janelle O.

39. Heirs of Sps Ramiro vs Bacaron

PETITIONER: THE HEIRS OF THE LATE SPOUSES ALEJANDRO RAMIRO AND


FELICISIMA LLAMADA, NAMELY; HENRY L. RAMIRO; MERLYN R. TAGUBA; MARLON L.
RAMIRO; MARIDEL R. SANTELLA, WILMA L. RAMIRO; VILMA R. CIELO AND CAROLYN R.
CORDERO
RESPONDENT: SPOUSES ELEODORO AND VERNA BACARON
DATE: February 06, 2019
PONENTE: Jardaleza, J.
TOPIC: Jurisdiction

Facts:
● Sps Bacaron claimed that the father of petitioners sold the property to them
● The property, however, was earlier mortgaged by spouses Ramiro to the Development
Bank of the Philippines (DBP)
● Sps Bacaron paid the DBP P430,150.00 for the redemption of the property
● In June 1998, petitioners forcibly dispossessed spouses Bacaron of the property.
● Petitioners, on the other hand, denied the material allegations of the amended
complaint, raising the following affirmative defenses: that the RTC does not have
jurisdiction over the case considering that it involves recovery of possession of the
property;
Issues: Whether the RTC acquired jurisdiction over the subject matter of the action. - NO.
Ruling:
● While respondents’ claim that their amended complaint before the RTC is denominated
as one for the declaration of validity of the Deed of Sale and for specific performance,
the averments in their amended complaint and the character of the reliefs sought therein
reveal that the action primarily involves title to or possession of real property.
● An action "involving title to real property" means that the plaintiff's cause of action is
based on a claim that he owns such property or that he has the legal rights to have
exclusive control, possession, enjoyment, or disposition of the same. Title is the "legal
link between (1) a person who owns property and (2) the property itself."
● absent any allegation in the complaint of the assessed value of the property, it cannot be
determined which between the RTC or the Municipal Trial Court had original and
exclusive jurisdiction over respondents' action. Consequently, the complaint filed before
the RTC should be dismissed.
● Furthermore, it is not simply the filing of the complaint or appropriate initiatory pleading
but the payment of the prescribed docket fee that vests a trial court with jurisdiction over
the subject matter or nature of the action.
● In resolving the issue of whether or not the correct amount of docket fees were paid, it is
also necessary to determine the true nature of the complaint.
● Having settled that the action instituted by respondents is a real action and not one
incapable of pecuniary estimation, the basis for determining the correct docket fees
shall, therefore, be the assessed value of the property, or the estimated value thereof as
alleged by the claimant.
● As already discussed, however, respondents did not allege the assessed value of the
property in their amended complaint. They also did not allege its estimated value.
Manzano, Dawn Janelle O.

● As a result, the correct docket fees could not have been computed and paid by
respondents and the RTC could not have acquired jurisdiction over the subject matter of
the case. All the proceedings before it are consequently null and void.

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