In the Philippine legal system, determining the correct court to hear a case is crucial, as jurisdiction is conferred by law and affects the authority of a court to render judgment. The Supreme Court in Cabrera v. Clarin reiterated that in accion publiciana cases (plenary action to recover the right of possession), the assessed value of the property dictates which court has jurisdiction. This ruling emphasizes the need for plaintiffs to accurately state the assessed value of the property in their complaints; failure to do so can lead to dismissal of the case for lack of jurisdiction, even if the issue is raised belatedly.

Land Dispute Limbo: When Does a Court Truly Have the Power to Decide?

The case of Nestor Cabrera v. Arnel Clarin, et al., stemmed from a dispute over a parcel of agricultural land in Bulacan. Cabrera, claiming ownership under Transfer Certificate of Title No. T-4439, filed a complaint for accion publiciana against respondents who had allegedly encroached on portions of his property. The central legal question revolved around whether the Regional Trial Court (RTC) had jurisdiction over the case, given Cabrera’s failure to state the assessed value of the property in his complaint.

The respondents, in their motion to dismiss, argued that the complaint was defective due to the absence of the assessed value of the property, which is essential for determining the correct docket fees and the court’s jurisdiction. The RTC initially denied the motion, but the Court of Appeals (CA) reversed this decision, holding that the RTC lacked jurisdiction because the assessed value was not stated in the complaint. This led to Cabrera’s petition to the Supreme Court, questioning whether the respondents were estopped from raising the issue of jurisdiction and whether the CA erred in not considering the tax declaration annexed to Cabrera’s brief.

The Supreme Court referred to Batas Pambansa Bilang 129, as amended by Republic Act No. 7691, which delineates the jurisdiction of Regional Trial Courts (RTCs) and Metropolitan Trial Courts (MTCs), Municipal Trial Courts (MTCs), and Municipal Circuit Trial Courts (MCTC) in civil actions involving title to or possession of real property. According to Section 19 and 33:

Section 19. Jurisdiction in civil cases. – Regional Trial Courts shall exercise exclusive original jurisdiction.

(2) In all civil actions which involve the title to, or possession of, real property, or any interest therein, where the assessed value of the property involved exceeds Twenty thousand pesos (P20,000,00) or, for civil actions in Metro Manila, where such value exceeds Fifty thousand pesos (P50,000.00) except actions for forcible entry into and unlawful detainer of lands or buildings, original jurisdiction over which is conferred upon the Metropolitan Trial Courts, Municipal Trial Courts, and Municipal Circuit Trial Courts;

x x x x

Sec. 33. Jurisdiction of Metropolitan Trial Courts, Municipal Trial Courts, and Municipal Circuit Trial Courts in Civil Cases. – Metropolitan Trial Courts, Municipal Trial Courts, and Municipal Circuit Trial Courts shall exercise:

(3) Exclusive original jurisdiction in all civil actions which involve title to, or possession of, real property, or any interest therein where the assessed value of the property or interest therein docs not exceed Twenty thousand pesos (P20,000.00) or, in civil actions in Metro Manila, where such assessed value does not exceed Fifty thousand pesos (P50,000.00) exclusive of interest, damages of whatever kind, attorney’s fees, litigation expenses and costs: Provided, That in cases of land not declared for taxation purposes, the value of such property shall be determined by the assessed value of the adjacent lots.

The Court emphasized that the **jurisdictional element in accion publiciana cases is the assessed value of the property**. The failure to state this value in the complaint is a critical omission that affects the court’s ability to determine whether it has jurisdiction over the case.

Cabrera argued that the respondents were estopped from raising the issue of jurisdiction because they had participated in all stages of the case and sought affirmative reliefs. He cited the doctrine of estoppel by laches, which prevents a party from invoking lack of jurisdiction at a late stage, particularly after actively participating in the case and seeking a favorable outcome. The Supreme Court relied on the case of Tijam v. Sibonghanoy, where a party was barred from questioning the court’s jurisdiction after invoking it to secure affirmative relief. The Court then contrasted that with Calimlim v. Ramirez, which clarified that the Tijam ruling was an exceptional case due to the presence of laches, which is the failure or neglect to assert a right within a reasonable time.

However, the Court found that the respondents were not estopped from challenging the RTC’s jurisdiction. Unlike the situation in Tijam, the respondents raised the issue of jurisdiction in their motion to dismiss, before filing their answer, thus the Court noted that respondents had not unduly delayed in asserting their objection to jurisdiction. The Court also found the circumstances differed from the Heirs of Villegas case because the respondents raised the jurisdictional issue before judgment on the merits, whereas in Heirs of Villegas, the petitioner only raised the issue on appeal. The Court highlighted the unfairness and inequity that the application of estoppel seeks to prevent, is not present here. The Court stated:

“The instant case does not involve a situation where a party who, after obtaining affirmative relief from the court, later on turned around to assail the jurisdiction of the same court that granted such relief by reason of an unfavorable judgment.”

Cabrera also argued that the CA erred in not considering the tax declaration attached to his brief, which he claimed cured the defect of not alleging the assessed value in the complaint. The Supreme Court rejected this argument, stating that courts can only consider evidence that has been formally offered. It cited Rule 132, Section 34 of the Rules of Court, which states that: “The court shall consider no evidence which has not been formally offered.” The Court acknowledged that they had allowed evidence to be admitted and considered without it being formally offered, but the first requirement is, “the same must have been duly identified by testimony duly recorded and, second, the same must have been incorporated in the records of the case.” In this case, it was not.

The Court emphasized that a formal offer is necessary to enable the trial judge to know the purpose for which the evidence is presented and to allow the opposing party to examine and object to its admissibility. The Court also noted that the tax declaration was never duly identified by testimony during the trial, nor was it included in the formal offer of evidence, therefore the CA was not required to review the document. Furthermore, the belated presentation of the tax declaration to prove the assessed value before the appellate court would not cure the glaring defect in the complaint.

Ultimately, the Supreme Court upheld the CA’s decision, reiterating that the RTC lacked jurisdiction over the case due to the absence of the assessed value of the property in the complaint. The Court emphasized that this jurisdictional defect could not be waived or cured by estoppel. As such, all proceedings in the RTC were null and void. A void judgment for want of jurisdiction is no judgment at all, and cannot be the source of any right nor the creator of any obligation.

FAQs

What is the main legal issue in this case?	The central issue is whether the Regional Trial Court (RTC) had jurisdiction over an accion publiciana case where the complaint failed to state the assessed value of the property involved. This omission is crucial because the assessed value determines which court has jurisdiction over real property disputes.
What is an accion publiciana?	An accion publiciana is a plenary action for recovery of possession of real property. It is a lawsuit filed by someone who has a right to possess a property but is not currently in possession.
Why is the assessed value of the property important in this case?	The assessed value of the property determines whether the RTC or the Metropolitan Trial Court (MTC) has jurisdiction over the case. If the assessed value exceeds a certain threshold (P20,000 in most areas, P50,000 in Metro Manila), the RTC has jurisdiction; otherwise, the MTC does.
What does it mean for a court to lack jurisdiction?	When a court lacks jurisdiction, it means it does not have the legal authority to hear and decide a particular case. Any judgment or order issued by a court without jurisdiction is considered void and has no legal effect.
What is estoppel, and how does it relate to this case?	Estoppel is a legal principle that prevents a party from asserting a right or claim that contradicts their previous actions or statements. Cabrera argued that the respondents were estopped from questioning the RTC’s jurisdiction because they participated in the proceedings.
Why wasn’t estoppel applied in this case?	The Supreme Court held that estoppel did not apply because the respondents raised the issue of jurisdiction in their motion to dismiss before filing their answer and thus were not unduly delayed in asserting their objection to jurisdiction. The Court also found the circumstances differed from the Heirs of Villegas case because the respondents raised the jurisdictional issue before judgment on the merits, whereas in Heirs of Villegas, the petitioner only raised the issue on appeal.
Can a tax declaration be used to prove the assessed value of a property?	Yes, a tax declaration can be used to prove the assessed value, but it must be properly presented as evidence during the trial. In this case, the tax declaration was only attached to Cabrera’s brief on appeal and was never formally offered as evidence.
What is the consequence of a court lacking jurisdiction?	If a court lacks jurisdiction, its decision is considered void, meaning it has no legal effect. Any actions taken based on that decision are also invalid.
What happens if the assessed value is not stated in the complaint?	If the assessed value is not stated in the complaint, the court cannot determine whether it has jurisdiction over the case. As a result, the case may be dismissed for lack of jurisdiction.
What should a plaintiff do to ensure the court has jurisdiction in an accion publiciana case?	To ensure the court has jurisdiction, the plaintiff must clearly state the assessed value of the property in the complaint. They should also be prepared to present evidence, such as a tax declaration, to support the stated assessed value.

The Supreme Court’s decision in Cabrera v. Clarin underscores the critical importance of properly establishing jurisdiction in real property disputes. Litigants must ensure that their complaints clearly state the assessed value of the property to avoid potential dismissal for lack of jurisdiction. This case serves as a reminder of the fundamental principle that jurisdiction is conferred by law and cannot be waived or presumed.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: Nestor Cabrera, vs. Arnel Clarin and Wife; Milagros Barrios and Husband; Aurora Serafin and Husband; and Bonifacio Moreno and Wife, G.R. No. 215640, November 28, 2016