Foronda-Crystal vs. Son

In civil actions involving title to or possession of real property, jurisdiction over the subject matter is determined by the assessed value of the property as alleged in the complaint or ascertainable from documents attached thereto; failure to allege the assessed value, or an assessed value below the jurisdictional threshold, renders the RTC's judgment null and void.

Petitioner is the daughter of Eddie Foronda, the registered owner of a parcel of land in Compostela, Cebu, under Free Patent No. VII-519533 and OCT No. OP-37324. Respondent claimed ownership of the same lot, alleging she purchased it from Eleno T. Arias in 1986. The dispute centers on an action for reconveyance filed by respondent against petitioner, challenging the validity of the free patent and title issued to petitioner's father.

Petitioner Glynna Foronda-Crystal is the daughter of Eddie Foronda, the registered owner of a parcel of land in Barrio Magay, Compostela, Cebu, covered by Free Patent No. VII-519533 and OCT No. OP-37324. On March 15, 1999, respondent Aniana Lawas Son filed an action for reconveyance and damages against petitioner, alleging that she had been the lawful owner and possessor of the lot for twelve and a half years after purchasing it from Eleno T. Arias on August 4, 1986 for P200,000.00. Respondent claimed she religiously paid real property taxes under Tax Declaration No. 16408A and asserted that the issuance of the free patent to petitioner's father was due to gross error, pointing out that there was no tax declaration in Eddie Foronda's name.

Petitioner moved to dismiss the complaint on grounds of lack of jurisdiction, improper venue, prescription, and lack of cause of action. The RTC initially dismissed the case for lack of jurisdiction, noting that the market value of the property per Tax Declaration No. 16408A was P2,830.00, placing jurisdiction with the Municipal Circuit Trial Court. However, upon respondent's motion for reconsideration, the RTC reconsidered and set aside its earlier ruling, stating that the complaint alleged the property was worth P200,000.00, taking judicial notice of BIR zonal valuation, and holding that tax declarations are sometimes undervalued and not controlling.

Trial ensued, and on November 24, 2006, the RTC rendered a decision in favor of respondent, declaring the issuance of OCT No. OP-37324 a grave error and ordering the Register of Deeds to cancel it and issue a new title in respondent's name. Petitioner appealed to the CA, arguing that the RTC rendered its decision with undue haste, that respondent failed to prove the lot she acquired was Lot No. 1280, that respondent failed to prove actual physical possession, and that the action was barred by prescription and laches. On March 12, 2015, the CA affirmed the RTC decision, and subsequently denied petitioner's motion for reconsideration on October 19, 2015. Petitioner then elevated the case to the Supreme Court via a Petition for Review on Certiorari under Rule 45. During the proceedings, petitioner asserted that the assessed value of the property as stated in the tax declaration was merely P1,030.00, and therefore the RTC lacked jurisdiction.

• Jurisdiction: Petitioner argued that the RTC lacked jurisdiction over the case because the assessed value of the property was only P1,030.00, placing it within the jurisdiction of the first-level courts.
• Validity of RTC Decision: Petitioner maintained that the RTC proceedings and judgment were void ab initio for having been rendered without jurisdiction.
• Prescription and Laches: Petitioner argued that the action for reconveyance was already barred by prescription and laches.
• Public Grant: Petitioner asserted that Lot No. 1280 was a public grant to which Eddie Foronda was issued a free patent, and Article 434 of the Civil Code should apply.
• Undue Haste: Petitioner contended that the validity and integrity of the RTC decision was questionable because it was rendered with undue haste before the expiration of the period for filing memoranda.

• Jurisdiction: Whether the RTC validly acquired jurisdiction over the case, and whether the RTC decision was void ab initio.
• Validity of Title: Whether the OCT issued under the name of petitioner's father should be canceled and set aside on the strength of respondent's allegations of ownership.
• Prescription: Whether the action was already barred by prescription.

• Jurisdiction: No. The RTC did not acquire jurisdiction over the case, rendering its decision void ab initio, because the assessed value of the property as shown in the tax declaration attached to the complaint was only P2,826.00, which falls under the exclusive original jurisdiction of the MTC.
• Validity of Title: N/A
• Prescription: N/A

• Jurisdiction: Under the Judiciary Reorganization Act of 1980, as amended by R.A. No. 7691, the RTC has exclusive original jurisdiction over civil actions involving title to or possession of real property where the assessed value exceeds P20,000.00; otherwise, jurisdiction lies with the first-level courts. Jurisdiction is determined by the assessed value, not the fair market value, as alleged in the complaint. While the complaint failed to allege the assessed value, a liberal interpretation allows examination of documents attached to the complaint. The tax declaration attached as Annex "B" showed an assessed value of P2,826.00. Thus, the RTC lacked jurisdiction, and its decision was void. A void judgment cannot be the source of any right or obligation.
• Validity of Title: N/A
• Prescription: N/A

• Jurisdiction over real actions — In civil actions involving title to or possession of real property, the jurisdiction of the court is determined by the assessed value of the property as alleged in the complaint. If the assessed value is not alleged, a liberal interpretation allows the court to examine documents attached to the complaint to determine the assessed value. If the assessed value does not exceed P20,000.00 (or P50,000.00 in Metro Manila), jurisdiction lies with the first-level courts (MTC, MeTC, MCTC, MTCC), not the RTC.
• Void judgment for lack of jurisdiction — A judgment rendered by a court without jurisdiction is null and void. It cannot be the source of any right nor the creator of any obligation. It has no legal or binding effect and may be entirely disregarded.

• "Generally, the court should only look into the facts alleged in the complaint to determine whether a suit is within its jurisdiction. There may be instances, however, when a rigid application of this rule may result in defeating substantial justice or in prejudice to a party's substantial right." — This passage articulates the exception to the strict rule of determining jurisdiction solely from the complaint's allegations, allowing consideration of attached documents like tax declarations.
• "A void judgment is not entitled to the respect accorded to a valid judgment, but may be entirely disregarded or declared inoperative by any tribunal in which effect is sought to be given to it. It has no legal or binding effect or efficacy for any purpose or at any place." — This defines the legal effect of a void judgment, emphasizing that a judgment rendered without jurisdiction creates no rights or obligations.

• Heirs of Concha, Sr. vs. Spouses Lumocso — Cited to establish that jurisdiction in real actions is determined by the assessed value of the property, not the fair market value, pursuant to the Judiciary Reorganization Act of 1980, as amended.
• Spouses Cruz vs. Spouses Cruz, et al. — Followed to support the rule that jurisdiction is determined by facts alleged in the complaint, and failure to allege assessed value results in dismissal.
• Tumpag vs. Tumpag — Cited to establish the exception that the assessed value may be determined from documents attached to the complaint, allowing a liberal interpretation of the rule.
• Barangay Piapi vs. Talip and Trayvilla vs. Sejas — Distinguished. These cases used market value to determine jurisdiction, but the Court clarified they pertained to the payment of filing and docket fees under Rule 141 of the Rules of Court, not the delineation of jurisdiction between first and second-level courts under B.P. 129.
• Maslag vs. Monzon — Cited to support the ruling that a court's declaration of jurisdiction when it has none amounts to usurpation of jurisdiction.
• Diona vs. Balangue and Cañero vs. University of the Philippines — Cited to support the doctrine that a void judgment for want of jurisdiction is no judgment at all and creates no rights or obligations.

• Section 19(2), Batas Pambansa Blg. 129 (Judiciary Reorganization Act of 1980), as amended by Republic Act No. 7691 — Grants RTCs 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(3), Batas Pambansa Blg. 129, as amended by Republic Act No. 7691 — Grants first-level courts (MeTC, MTC, MCTC, MTCC) exclusive original jurisdiction over civil actions involving title to or possession of real property where the assessed value does not exceed P20,000.00.
• Section 7, Rule 141 of the Rules of Court — Concerns legal fees and the payment of prescribed filing and docket fees, which the Court clarified is distinct from the delineation of jurisdiction between first and second-level courts.

Carpio (Chairperson), Peralta, Perlas-Bernabe, and Caguioa, JJ., concur.