Berbano vs. Heirs of Roman Tapulao

Jurisdiction over real property actions is determined by the assessed value of the entire property as alleged in the complaint, not by the value of the specific portion actually occupied or disputed by the defendant. Where the complaint alleges an assessed value exceeding P20,000.00, the Regional Trial Court acquires jurisdiction regardless of the defendant's claim that only a portion of lesser value is in controversy.

Roman Tapulao was the registered owner of a parcel of land located in Taguing, Baggao, Cagayan, covered by Original Certificate of Title No. P-9331 with a total area of 18,512 square meters. Upon his death and that of his wife Catalina Casabar-Tapulao, their children (respondents) paid realty taxes and caused a relocation survey of the lot. The survey revealed that petitioners Joaquin, Trinidad, and Melchor Berbano occupied portions of the property. Despite demands to vacate, petitioners refused, claiming that Joaquin Berbano had acquired possession of half a hectare from the original owner Felipe Peña in 1954 and that Roman Tapulao's registration erroneously included this portion.

• Nature of the Action: Respondents instituted a Complaint for Recovery of Possession and Damages against petitioners, seeking to recover possession of a parcel of land registered under Original Certificate of Title No. P-9331 located in Taguing, Baggao, Cagayan.
• Property Details: The lot has a total area of 18,512 square meters and an assessed value of P22,070.00 as declared for taxation purposes under Tax Declaration No. 03-06042-00175.
• Occupation by Petitioners: A relocation survey conducted by respondents revealed that petitioners occupied a specific portion of the lot measuring approximately 6,804 square meters. Petitioners claimed this portion was ceded to Joaquin Berbano by the original owner Felipe Peña in 1954, and that Roman Tapulao's registration erroneously included this adjacent lot.
• Procedural Posture: The case underwent multiple pre-trial resets. On January 30, 2014, petitioners failed to appear at the scheduled pre-trial conference despite notice, leading the trial court to allow respondents to present evidence ex-parte.
• Lower Court Ruling: The RTC rendered judgment declaring respondents as rightful owners and ordering petitioners to vacate the occupied portion and pay actual damages of P4,131.00.
• Belated Jurisdictional Challenge: For the first time in their Motion for Reconsideration before the RTC, petitioners raised the issue of jurisdiction, arguing that since only 6,804 square meters were in dispute, the assessed value of the disputed portion (computed at P8,111.72) fell within the jurisdiction of the Municipal Trial Courts.

• Jurisdictional Determination: Petitioners argued that the RTC lacked jurisdiction because the real subject matter of the case was only the 6,804 square meter portion occupied by them, which carried an assessed value of only P8,111.72 (computed at P1.19219965 per square meter), well below the P20,000.00 threshold for RTC jurisdiction under Section 19 of Batas Pambansa Blg. 129, as amended.
• Procedural Defect: Petitioners maintained that they were not notified of the pre-trial conference dated January 30, 2014, justifying their failure to appear.
• Merits of Ownership: Petitioners asserted that Joaquin Berbano had been in open and exclusive possession of the disputed portion since 1954 based on a cession from Felipe Peña, and that Roman and Catalina Tapulao had acknowledged the survey error in an Affidavit dated April 2, 1976, promising to respect Joaquin's ownership.

• Jurisdictional Allegations: Respondents countered that the nature of the action and the value of the subject matter are determined by the allegations in the complaint, which specifically alleged an assessed value of P22,070.00 for the entire lot, thereby vesting jurisdiction in the RTC.
• Estoppel: Respondents argued that petitioners were estopped from questioning jurisdiction after having filed an Answer and actively sought affirmative relief (dismissal of the case, transfer of registration, and damages) before the trial court.
• Procedural Compliance: Respondents maintained that proper notice of the pre-trial was served upon petitioners, and their repeated failure to appear warranted the presentation of evidence ex-parte.

• Jurisdiction over the Subject Matter: Whether the RTC had jurisdiction over the action for recovery of possession where the assessed value of the entire lot alleged in the complaint exceeded P20,000.00, notwithstanding petitioners' claim that only a portion of lesser value was in dispute.
• Estoppel by Laches: Whether petitioners were barred from questioning the trial court's jurisdiction after having invoked it to seek affirmative relief.

• Jurisdiction Determined by Complaint Allegations: Jurisdiction over the subject matter is conferred by law and determined by examining the material allegations of the complaint and the relief sought. The complaint expressly alleged that the assessed value of the subject property was P22,070.00, which exceeds the P20,000.00 threshold for RTC jurisdiction under Section 19 of Batas Pambansa Blg. 129, as amended by Republic Act No. 7691.
• Portion vs. Whole Property: The claim that jurisdiction should be determined by the value of only the disputed portion (P8,111.72) is irrelevant and constitutes an impermissible attempt by defendants to define the plaintiffs' cause of action. The assessed value of the entire property as alleged in the complaint controls for jurisdictional purposes, as the contiguous portion could be relevant to remedies such as burden of improvements and indicators of good or bad faith.
• Active Participation as Estoppel: A party cannot invoke the jurisdiction of a court to seek affirmative relief and subsequently repudiate that jurisdiction after failing to obtain favorable judgment. Having filed an Answer praying for dismissal, transfer of title, and damages, petitioners were estopped from questioning jurisdiction for the first time in a motion for reconsideration after an adverse decision.
• Procedural History: The petition was denied and the Court of Appeals' decision affirming the trial court's jurisdiction was sustained.

• Determination of Jurisdiction by Complaint Allegations — Jurisdiction over the subject matter is determined by the material allegations of the complaint and the character of the relief sought, not by the defenses raised in the answer or the evidence to be presented. The court must look at the averments in the initiatory pleading to ascertain the nature of the claim and the relief prayed for.
• Estoppel by Laches in Jurisdictional Challenges — A party who invokes the jurisdiction of a court by filing responsive pleadings and seeking affirmative relief is estopped from later questioning that same jurisdiction after obtaining or failing to obtain such relief. This doctrine prevents parties from playing "fast and loose" with the judicial system.
• Jurisdictional Threshold for Real Property Cases — Under Section 19 of Batas Pambansa Blg. 129, as amended by Republic Act No. 7691, the Regional Trial Court has exclusive original jurisdiction over civil actions involving title to or possession of real property where the assessed value exceeds P20,000.00 (or P50,000.00 in Metro Manila), while Municipal Trial Courts have jurisdiction where the assessed value does not exceed P20,000.00.

• "Jurisdiction is defined as the power and authority of a court to hear, try, and decide a case. In order for the court or an adjudicative body to have authority to dispose of the case on the merits, it must acquire, among others, jurisdiction over the subject matter. Jurisdiction over the subject matter is the power to hear and determine the general class to which the proceedings in question belong; it is conferred by law and not by the consent or acquiescence of any or all of the parties or by erroneous belief of the court that it exists."
• "The Court has repeatedly held that jurisdiction over the subject matter is determined by examining the material allegations of the complaint and the relief sought."
• "It is not for petitioners to define the allegations in their adversaries' complaint. That is the respondents' prerogative as plaintiffs below."
• "A party cannot invoke the jurisdiction of a court and ask for affirmative relief against his opponent and, after obtaining or failing to obtain such relief, repudiate or question that same jurisdiction."

• Tijam, et al. v. Sibonghanoy, et al., 131 Phil. 556 (1968) — Controlling precedent establishing the doctrine of estoppel by laches; followed to bar petitioners from belatedly challenging jurisdiction after actively invoking it to seek affirmative relief.
• Editha Padlan v. Elenita Dinglasan, et al., 707 Phil. 83 (2013) — Cited for the principle that jurisdiction is determined by examining the material allegations of the complaint and the relief sought.
• Glynna Foronda-Crystal v. Aniana Lawas Son, G.R. No. 221815, November 29, 2017 — Cited for the definition of jurisdiction and jurisdiction over the subject matter.

• Section 19, Batas Pambansa Blg. 129, as amended by Republic Act No. 7691 — Grants the Regional Trial Court exclusive original jurisdiction over civil actions involving title to or possession of real property where the assessed value exceeds P20,000.00 (or P50,000.00 in Metro Manila).
• Section 33, Batas Pambansa Blg. 129 — Grants Metropolitan Trial Courts, Municipal Trial Courts, and Municipal Circuit Trial Courts exclusive original jurisdiction over civil actions involving title to or possession of real property where the assessed value does not exceed P20,000.00 (or P50,000.00 in Metro Manila).

Carpio (Chairperson), Perlas-Bernabe, Caguioa, and J. Reyes, Jr., JJ.