REMEDIAL LAW | Padlan vs. Dinglasan G.R. No. 180321, March 20 2013

Padlan vs. Dinglasan 

G.R. No. 180321, March 20 2013


FACTS Elenita Dinglasan (Elenita) was the registered owner of a parcel of land covered by TCT No. T-105602. While on board a jeepney, Elenita's mother, Lilia Baluyot (Lilia), had a conversation with one Maura Passion (Maura) regarding the sale of said property. Believing that Maura was a real estate agent, Lilia borrowed the owner's copy of the TCT from Elenita and gave it to Maura. Maura then subdivided the property into several lots under the name of Elenita and her husband Felicisimo. Through a falsified deed of sale bearing forged signature of Elenita and Felicisimo, Maura was able to sell the lots to different buyers, one of whom was Lorna Ong (Lorna). Sometime in August 1990, Lorna sold the lot to Editha Padlan for P4,000. After learning what happened, Elenita demanded Padlan to surrender possession of said land, but the latter refused. Respondents files a case before the RTC of Balanga, Bataan and summons to petitioner was thereafter served. On December 13, 1999, respondents moved to declare petitioner in default and prayed that they be allowed to present evidence ex parte. Petitioner opposed the same contending that the court did not have jurisdiction over the subject matter and over her person. Whether or not the court acquired jurisdiction over the subject matter and the person of the petitioner.


RULING No. In order to determine which court has jurisdiction over the action, an examination of the complaint is essential. Basic as hornbook principle is that jurisdiction over the subject matter of a case is conferred by law and determined by the allegations in the complaint which comprise a concise statement of the ultimate facts constituting the plaintiff's cause of action.


Here, respondents filed the complaint in 1999, at the time BP 129, the Judiciary Reorganization Act of 1980, was already amended by RA No. 7691, An Act Expanding the Jurisdiction of the Metropolitan Trial Courts, Municipal Trial Courts, and Municipal Circuit Trial Courts. Section 3 of RA 7691 expanded the exclusive original jurisdiction of the first level courts to include all civil actions which involve title to, or possession, of real property, or any interest therein which does not exceed P20,000 or, in civil actions in Metro Manila, where such assessed value does not exceed P50, 000. In this case, the only basis of valuation of the subject property is the value alleged in the complaint that the lot was sold in the amount of P4, 000. No tax declaration was even presented that would show the valuation of the subject property. Since the amount alleged is only P4, 000, the MTC and not the RTC has jurisdiction over the action. 







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