Heirs of Valeriano S. Concha, Sr. vs. Spouses Gregorio J. Lumocso, et al.

In civil actions for reconveyance or to remove cloud on title over real property, jurisdiction is governed by Section 19(2) of B.P. 129, as amended by R.A. No. 7691, and is determined solely by the assessed value of the real property involved; where that assessed value does not exceed P20,000.00, the MTC has exclusive original jurisdiction, and the value of trees cut or other damages cannot be added to the assessed value to bring the case within the RTC's jurisdiction.

Petitioners are the heirs of spouses Dorotea and Valeriano Concha, Sr., who had acquired a 24-hectare homestead in Cogon, Dipolog City; petitioners claim the disputed lots as excess forest land adjoining that homestead under Section 48(b) of Commonwealth Act No. 141, as amended by Republic Act No. 1942. Respondents are the Lumocso siblings, who hold free patents and original certificates of title over the disputed lots. The jurisdictional dispute arises against the backdrop of Section 19 of Batas Pambansa Blg. 129, as amended by Republic Act No. 7691, which allocates original jurisdiction over civil actions involving title to or possession of real property according to the assessed value of the property.

Petitioners are the heirs of spouses Dorotea and Valeriano Concha, Sr. They claim to be the rightful owners of Lot No. 6195 (Civil Case No. 5188), a one-hectare portion of Lot No. 6196-A (Civil Case No. 5433), and a one-hectare portion of Lot Nos. 6196-B and 7529-A (Civil Case No. 5434), all situated in Cogon, Dipolog City, under Section 48(b) of Commonwealth Act No. 141, the Public Land Act. Respondents are siblings Gregorio Lumocso (Civil Case No. 5188), Cristita Lumocso Vda. de Daan (Civil Case No. 5433), and Jacinto Lumocso (Civil Case No. 5434), the patent holders and registered owners of the subject lots.

The complaints commonly alleged that on May 21, 1958, the Concha spouses acquired by homestead a 24-hectare parcel of land in Cogon, Dipolog City; that since 1931 they had "painstakingly preserved" the forest in the 24-hectare land, including the excess four hectares of untitled forest land on its eastern portion; and that they possessed the excess four hectares—Lot No. 6195, a one-hectare portion of Lot No. 6196-A, and a one-hectare portion of Lot Nos. 6196-B and 7529-A—continuously, publicly, notoriously, adversely, peacefully, in good faith, and in concept of owner since 1931. They continued possession and occupation after Dorotea Concha died on December 23, 1992 and Valeriano Sr. died on May 12, 1999. They allegedly preserved the forest trees standing on the subject lots to the exclusion of respondents or other persons from 1931 until November 12, 1996 (for Civil Case No. 5188) or January 1997 (for Civil Case Nos. 5433 and 5434), when respondents, by force, intimidation, and stealth, forcibly entered the premises and illegally cut, collected, and disposed of 21 trees (Civil Case No. 5188), 22 trees (Civil Case No. 5433), and 6 trees (Civil Case No. 5434). They further alleged that respondents cut into flitches the trees felled in Lot No. 6195, while the logs taken from the subject lots in Civil Case Nos. 5433 and 5434 were sold to a timber dealer in Katipunan, Zamboanga del Norte. They also alleged that respondents surreptitiously filed free patent applications over the lots despite full knowledge that petitioners owned them; that the geodetic engineers who conducted the original survey never informed petitioners of the survey to give them an opportunity to oppose the applications; that the free patents and corresponding OCTs were issued on account of fraud, deceit, bad faith, and misrepresentation; and that the lots had not been transferred to an innocent purchaser.

On August 6, 1997, Valeriano Sr. and his children filed a complaint for Reconveyance and/or Annulment of Title with Damages against Spouses Gregorio Lomocso and Bienvenida Guya, seeking to annul Free Patent No. (IX-8)985 and the corresponding Original Certificate of Title No. P-22556 issued in the name of Gregorio Lumocso covering Lot No. 6195. The case was raffled to the RTC of Dipolog City, Branch 9, and docketed as Civil Case No. 5188. In their Amended Complaint, petitioners prayed for a declaration that the free patent and OCT were null and void ab initio; a declaration that Lot No. 6195 or 1.19122 hectares was the private property of the plaintiffs under Section 48(b) of C.A. No. 141, as amended by R.A. No. 1942; an order for reconveyance within 30 days from finality, with the Clerk of Court authorized to execute the deed if respondents refused; payment of P60,000.00 for 21 forest trees illegally cut, P50,000.00 moral damages, P20,000.00 attorney's fees, P20,000.00 litigation expenses, and costs; and a declaration that the confiscated three flitches kept in the area of the plaintiffs at Dampalan San Jose, Dipolog, with a total volume of 2,000 board feet, were the property of the plaintiffs.

On September 3, 1999, two separate complaints for Reconveyance with Damages were filed. One was against Cristita Lumocso Vda. de Daan for a one-hectare portion of Lot No. 6196-A, docketed as Civil Case No. 5433; the other was against Spouses Jacinto Lumocso and Balbina T. Lumocso for a one-hectare portion of Lot Nos. 6196-B and 7529-A, docketed as Civil Case No. 5434. Both were raffled to Branch 9 of the RTC of Dipolog City. In Civil Case No. 5433, petitioners prayed for a declaration that the one-hectare western portion of Lot No. 6196-A titled under OCT (P23527) 4888 was their private property under Section 48(b) of C.A. No. 141, as amended by R.A. No. 1942; for reconveyance of that portion within 30 days from finality, with the Clerk of Court authorized to execute the deed if the defendant refused; and for P30,000.00 for 22 forest trees illegally cut, P20,000.00 moral damages, P20,000.00 attorney's fees, P20,000.00 litigation expenses, and costs. In Civil Case No. 5434, petitioners prayed for a declaration that the one-hectare western portion of Lot No. 7529-A under OCT (P-23207) 12870 and Lot No. 6196-B under OCT (P-20845) 4889 was their private property under Section 48(b); for reconveyance of that portion within 30 days from finality, with the Clerk of Court authorized to execute the deed if the defendants refused; and for P20,000.00 for six forest trees illegally cut, P20,000.00 moral damages, P20,000.00 attorney's fees, P20,000.00 litigation expenses, and costs.

It was undisputed that the subject lots are situated in Cogon, Dipolog City and that their assessed values are less than P20,000.00: Lot No. 6195, P1,030.00; Lot No. 6196-A, P4,500.00; Lot No. 6196-B, P4,340.00; and Lot No. 7529-A, P1,880.00.

• Prematurity of Dismissal: Petitioners argued that the Court of Appeals erred in reversing the RTC order denying the motions to dismiss, considering that dismissal of a complaint is premature and trial on the merits should be conducted to thresh out evidentiary matters.
• Prescription: Petitioners argued that the Court of Appeals erred in dismissing the complaints on the ground of prescription.
• Ownership Evidence: Petitioners argued that the Court of Appeals erred in concluding that there is no documentary evidence on record to show that petitioners own the subject forest portion of the properties erroneously included in respondents' titles.
• Procedural Compliance with Rule 65: Petitioners argued that respondents' petition filed with the Court of Appeals should have been dismissed outright for failure to comply with the mandatory requirement of Section 1, Rule 65 of the Rules of Court to submit certified true copies of the assailed orders, citing Catuira vs. Court of Appeals (172 SCRA 136).
• Jurisdiction — Incapable of Pecuniary Estimation: Petitioners contended that the complaints are suits for reconveyance, or annulment or cancellation of OCTs and damages; that the cases involve more than just title and possession because the nullity of the OCTs and the reconveyance of the subject properties were raised; and that the RTC has jurisdiction under Section 19(1) of B.P. 129, which covers civil actions in which the subject of the litigation is incapable of pecuniary estimation. They cited Raymundo vs. Court of Appeals, Swan vs. Court of Appeals, Santos vs. Court of Appeals, and Commodities Storage and ICE Plant Corporation vs. Court of Appeals.
• Jurisdiction — Totality of Claims and Value of Trees: Petitioners also contended that while the assessed values of the subject properties are within the original jurisdiction of the MTC, they included in their prayers "any interest included therein" consisting of 49 felled natural grown trees illegally cut by respondents; combining the assessed values and the estimated value of the trees cut, the total amount prayed exceeds P20,000.00, so the RTC has jurisdiction under Section 19(2) of B.P. 129.

• Lack of Jurisdiction: Respondents contended that the RTC has no jurisdiction over the complaints pursuant to Section 19(2) of B.P. 129, as amended by R.A. No. 7691, as in each case the assessed values of the subject lots are less than P20,000.00.
• Failure to State a Cause of Action: Respondents argued that the complaints do not state causes of action for reconveyance.
• Prescription: Respondents argued that, assuming the complaints state causes of action for reconveyance, the same have already been barred by prescription.
• Waiver, Abandonment, Laches, and Estoppel: Respondents argued that the claims for reconveyance in the complaints are barred by waiver, abandonment, or otherwise extinguished by laches and estoppel.
• No Special Reason for Review: Respondents argued that there is no special reason warranting a review by the Supreme Court.

• Jurisdiction: Whether the RTC has jurisdiction over the complaints for reconveyance and/or annulment of title with damages, or whether jurisdiction belongs to the MTC under Section 19(2) of B.P. 129, as amended by R.A. No. 7691, based on the assessed value of the subject real property.
• Propriety of Dismissal Before Trial: Whether the Court of Appeals erred in reversing the RTC order denying the motions to dismiss, considering that dismissal of a complaint is premature and trial on the merits should be conducted to thresh out evidentiary matters.
• Prescription: Whether the Court of Appeals erred in dismissing the complaints on the ground of prescription.
• Ownership Evidence: Whether the Court of Appeals erred in concluding that there is no documentary evidence on record to show that petitioners own the subject forest portion of the properties erroneously included in respondents' titles.
• Procedural Compliance with Rule 65: Whether respondents' petition filed with the Court of Appeals should have been dismissed outright for failure to comply with the mandatory requirement of Section 1, Rule 65 of the Rules of Court to submit certified true copies of the assailed orders, citing Catuira vs. Court of Appeals.

• Jurisdiction: No. The RTC of Dipolog City, Branch 9, had no jurisdiction over Civil Case Nos. 5188, 5433, and 5434. The complaints were in the nature of actions for reconveyance or to remove cloud on title, which involve title to or possession of real property under Section 19(2) of B.P. 129, as amended by R.A. No. 7691; because the assessed values of the subject lots were less than P20,000.00, exclusive original jurisdiction belonged to the MTC.
• Propriety of Dismissal Before Trial: Not reached. The Court resolved the case on the jurisdictional ground and did not pass upon this issue.
• Prescription: Not reached. The Court resolved the case on the jurisdictional ground and did not pass upon this issue.
• Ownership Evidence: Not reached. The Court resolved the case on the jurisdictional ground and did not pass upon this issue.
• Procedural Compliance with Rule 65: Not reached. The Court resolved the case on the jurisdictional ground and did not pass upon this issue.

• Jurisdiction: Jurisdiction over the subject matter is the power to hear and determine cases of the general class to which the proceedings in question belong; it is conferred by law and an objection based on this ground cannot be waived by the parties. To determine whether a court has jurisdiction, the nature of the cause of action and the relief sought must be examined. The trial court correctly held that the instant cases involve actions for reconveyance. An action for reconveyance respects the decree of registration as incontrovertible but seeks the transfer of property wrongfully or erroneously registered in other persons' names to its rightful and legal owners, or to those who claim a better right. There is no special ground for an action for reconveyance; it is enough that the aggrieved party has a legal claim on the property superior to that of the registered owner and that the property has not yet passed to the hands of an innocent purchaser for value. The reliefs sought by petitioners typify an action for reconveyance, and the common allegations in the three complaints—ownership and possession since 1931, preservation of forest trees, forcible entry and illegal cutting by respondents, acquisition of imperfect title under Section 48(b) of C.A. No. 141, surreptitious patent applications, issuance of patents and OCTs through fraud, deceit, bad faith, and misrepresentation, and lack of transfer to an innocent purchaser—are sufficient to constitute causes of action for reconveyance. The cases may also be considered actions to remove cloud on title, as they are intended to procure the cancellation of an instrument constituting a claim on petitioners' alleged title which was used to injure or vex them in the enjoyment of that title. Being in the nature of actions for reconveyance or actions to remove cloud on title, the applicable law to determine jurisdiction is Section 19(2) of B.P. 129, as amended by R.A. No. 7691, which grants the RTC exclusive original jurisdiction in all civil actions involving title to, or possession of, real property, or any interest therein, where the assessed value of the property involved exceeds P20,000.00, or P50,000.00 in Metro Manila, except actions for forcible entry and unlawful detainer. In the cases at bar, it is undisputed that the subject lots are situated in Cogon, Dipolog City and their assessed values are less than P20,000.00: Lot No. 6195, P1,030.00; Lot No. 6196-A, P4,500.00; Lot No. 6196-B, P4,340.00; and Lot No. 7529-A, P1,880.00. Hence, the MTC clearly has jurisdiction. Petitioners' contention that the cases are incapable of pecuniary estimation under Section 19(1) of B.P. 129 is erroneous. In a number of cases, actions for reconveyance of, or for cancellation of title to, or to quiet title over real property have been held to fall under the classification of cases that involve title to, or possession of, real property, or any interest therein. The original text of Section 19(2) of B.P. 129, as well as its forerunner Section 44(b) of R.A. No. 296, as amended, gave the RTCs, formerly courts of first instance, exclusive original jurisdiction in all civil actions involving title to, or possession of, real property, or any interest therein, except forcible entry and unlawful detainer. Under the old law, there was no substantial effect on jurisdiction whether a case was incapable of pecuniary estimation under Section 19(1) or involved title to property under Section 19(2). The distinction became crucial with the amendment introduced by R.A. No. 7691 in 1994, which expanded the exclusive original jurisdiction of the first-level courts to include all civil actions involving title to, or possession of, real property, or any interest therein where the assessed value of the property or interest therein does not exceed P20,000.00, or P50,000.00 in Metro Manila, exclusive of interest, damages of whatever kind, attorney's fees, litigation expenses, and costs. Thus, under the present law, original jurisdiction over cases involving title to, possession of, real property, or any interest therein under Section 19(2) of B.P. 129 is divided between the first and second level courts, with the assessed value of the real property involved as the benchmark. This amendment was introduced to unclog the overloaded dockets of the RTCs and to result in the speedier administration of justice. Raymundo vs. Court of Appeals and Commodities Storage and ICE Plant Corporation vs. Court of Appeals, relied upon by petitioners, are inapplicable. Raymundo involved a complaint for mandatory injunction, not one for reconveyance or annulment of title; the issue was whether the case was incapable of pecuniary estimation, and the claim for attorney's fees was merely incidental to the principal action. Commodities Storage and ICE Plant Corporation resolved the issue of venue, not jurisdiction, and the action therein was filed before the passage of R.A. No. 7691. Worse, Swan vs. Court of Appeals and Santos vs. Court of Appeals, cited by petitioners, contradict their own position that the nature of the instant cases falls under Section 19(1) of B.P. 129. The complaints in Swan and Santos were filed prior to the enactment of R.A. No. 7691. In Swan, the action being one for annulment of title, the RTC had original jurisdiction under Section 19(2) of B.P. 129. In Santos, the complaint for cancellation of title, reversion, and damages was also held to involve title to and possession of real property under Section 19(2) of B.P. 129. Thus, while the Court held that the RTC had jurisdiction, it classified actions for annulment of title and for cancellation of title, reversion, and damages as civil actions involving title to, or possession of, real property, or any interest therein under Section 19(2). Petitioners' contention that the value of the trees cut in the subject properties constitutes "any interest therein" that should be computed in addition to the assessed values is unavailing. Section 19(2) of B.P. 129, as amended by R.A. No. 7691, is clear that the RTC shall exercise jurisdiction where the assessed value of the property involved exceeds P20,000.00, or P50,000.00 in Metro Manila. It is true that the recovery of the value of the trees cut from the subject properties may be included in the term "any interest therein." However, the law is emphatic that in determining which court has jurisdiction, it is only the assessed value of the realty involved that should be computed. In this case, there is no dispute that the assessed values of the subject properties as shown by their tax declarations are less than P20,000.00. Clearly, jurisdiction over the instant cases belongs not to the RTC but to the MTC.
• Propriety of Dismissal Before Trial: Not reached. The Court resolved the case on jurisdiction and did not pass upon this issue.
• Prescription: Not reached. The Court resolved the case on jurisdiction and did not pass upon this issue.
• Ownership Evidence: Not reached. The Court resolved the case on jurisdiction and did not pass upon this issue.
• Procedural Compliance with Rule 65: Not reached. The Court resolved the case on jurisdiction and did not pass upon this issue.

• Jurisdiction over the subject matter — It is the power to hear and determine cases of the general class to which the proceedings in question belong. It is conferred by law and an objection based on this ground cannot be waived by the parties. In this case, the Court examined jurisdiction even though the Court of Appeals had skirted the issue, because it was determinative of the resolution of the case.
• Determination of jurisdiction by nature of cause of action and relief sought — To determine whether a court has jurisdiction over the subject matter, the nature of the cause of action and the relief sought must be examined. The Court applied this by looking at the complaints' allegations and prayers, which typified reconveyance or removal of cloud on title.
• Action for reconveyance — An action for reconveyance respects the decree of registration as incontrovertible but seeks the transfer of property wrongfully or erroneously registered in another's name to its rightful and legal owners, or to those who claim a better right. There is no special ground; it is enough that the aggrieved party has a legal claim on the property superior to that of the registered owner and that the property has not yet passed to an innocent purchaser for value. The complaints alleged ownership and possession since 1931, fraud in the patents and OCTs, and that the lots had not been transferred to an innocent purchaser, and prayed for reconveyance.
• Action to remove cloud on title — It is intended to procure the cancellation of an instrument constituting a claim on one's title which was used to injure or vex the claimant in the enjoyment of the title. The Court held that the complaints could also be considered actions to remove cloud on title.
• Real property actions under Section 19(2) of B.P. 129 — Actions for reconveyance, cancellation of title, quiet title, and annulment of title over real property are actions involving "title to, or possession of, real property, or any interest therein" under Section 19(2) of B.P. 129. They are not actions incapable of pecuniary estimation under Section 19(1). Thus, jurisdiction is determined by the assessed value of the real property.
• Assessed value as the jurisdictional benchmark — Under Section 19(2) of B.P. 129, as amended by R.A. No. 7691, the RTC has exclusive original jurisdiction where the assessed value of the real property involved exceeds P20,000.00, or P50,000.00 in Metro Manila; first-level courts have jurisdiction where the assessed value does not exceed those amounts. The law is emphatic that only the assessed value of the realty involved should be computed; the value of trees cut or damages cannot be added to the assessed value to confer RTC jurisdiction. Because the assessed values were less than P20,000.00, the MTC had jurisdiction.
• R.A. No. 7691 and division of jurisdiction — R.A. No. 7691 expanded the exclusive original jurisdiction of first-level courts to include 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, exclusive of interest, damages, attorney's fees, litigation expenses, and costs. This divided original jurisdiction over such real property actions between first and second level courts, using assessed value as the benchmark, to unclog the RTC dockets. The Court applied this to hold that the MTC, not the RTC, had jurisdiction.

• "Jurisdiction over the subject matter is the power to hear and determine cases of the general class to which the proceedings in question belong." — This passage states the foundational definition of jurisdiction over the subject matter and frames the Court's inquiry into whether the RTC or MTC had authority over the complaints.
• "An action for reconveyance respects the decree of registration as incontrovertible but seeks the transfer of property, which has been wrongfully or erroneously registered in other persons' names, to its rightful and legal owners, or to those who claim to have a better right." — This is the Court's canonical definition of an action for reconveyance, which it used to classify the complaints and determine the proper jurisdictional provision.
• "Being in the nature of actions for reconveyance or actions to remove cloud on one's title, the applicable law to determine which court has jurisdiction is Section 19(2) of B.P. 129, as amended by R.A. No. 7691," — This passage is the ratio decidendi on jurisdiction: it classifies the complaints as real property actions and identifies the controlling jurisdictional provision.
• "However, the law is emphatic that in determining which court has jurisdiction, it is only the assessed value of the realty involved that should be computed." — This passage rejects petitioners' attempt to add the value of the trees cut to the assessed values, and it supplies the controlling rule for computing jurisdiction under Section 19(2).
• "Clearly, jurisdiction over the instant cases belongs not to the RTC but to the MTC." — This is the Court's direct conclusion on the jurisdictional issue, resolving the case in favor of the MTC.

• Hi-Tone Marketing Corp. vs. Baikal Realty Corp., G.R. No. 149992, August 20, 2004, 437 SCRA 121 — Cited for the definition of an action for reconveyance: it respects the decree of registration as incontrovertible but seeks transfer of property wrongfully or erroneously registered in another's name to the rightful owner.
• Philippine Economic Zone Authority vs. Fernandez, G.R. No. 138971, June 6, 2001, 358 SCRA 489 — Cited for the requirement that the property has not yet passed to an innocent purchaser for value for an action for reconveyance to prosper.
• Abrin vs. Campos, G.R. No. 52740, November 12, 1991, 203 SCRA 420; Estate of the late Mercedes Jacob vs. Court of Appeals, G.R. No. 120435, December 22, 1997, 283 SCRA 474 — Cited to support that actions for reconveyance of real property fall under cases involving title to or possession of real property.
• Santos vs. Court of Appeals, G.R. No. 61218, September 23, 1992, 214 SCRA 162 — Cited by petitioners but held to contradict their position; the complaint for cancellation of title, reversion, and damages was classified as an action involving title to and possession of real property under Section 19(2) of B.P. 129, although it was filed prior to R.A. No. 7691.
• Swan vs. Court of Appeals, G.R. No. 97319, August 4, 1992, 212 SCRA 114 — Cited by petitioners but held to contradict their position; an action for annulment of title fell under the RTC's original jurisdiction under Section 19(2) of B.P. 129, and the complaint was filed prior to R.A. No. 7691.
• Raymundo vs. Court of Appeals, G.R. No. 97805, September 2, 1992, 213 SCRA 457 — Distinguished; it involved a complaint for mandatory injunction, not reconveyance or annulment of title, and the issue was whether the action was incapable of pecuniary estimation, with attorney's fees merely incidental.
• Commodities Storage and ICE Plant Corporation vs. Court of Appeals, G.R. No. 125008, June 19, 1997, 274 SCRA 439 — Distinguished; the issue resolved was venue, not jurisdiction, and the action was filed before the passage of R.A. No. 7691.
• Hilario vs. Salvador, G.R. No. 160384, April 29, 2005, 457 SCRA 815 — Cited for the rule that in determining which court has jurisdiction, only the assessed value of the realty involved should be computed.
• Allied Domecq Phil., Inc. vs. Villon, G.R. No. 156264, September 30, 2004, 439 SCRA 667 — Cited for the principle that jurisdiction over the subject matter is conferred by law and cannot be waived by the parties.
• Republic vs. Sangalang, L-58822, April 8, 1988, 159 SCRA 515 — Cited for the rule that an objection based on lack of jurisdiction over the subject matter cannot be waived.
• Philippine Association of Free Labor Unions vs. Padilla, 106 Phil. 591 (1959) — Cited for the rule that the nature of the cause of action and the relief sought determine jurisdiction over the subject matter.
• Catuira vs. Court of Appeals, 172 SCRA 136 — Cited by petitioners in arguing that respondents' Court of Appeals petition should have been dismissed for failure to submit certified true copies of the assailed orders under Section 1, Rule 65; the Court did not resolve this issue because it decided the case on jurisdiction.

• Section 19(1), Batas Pambansa Blg. 129 — Grants the RTC exclusive original jurisdiction in all civil actions in which the subject of the litigation is incapable of pecuniary estimation. Petitioners invoked it; the Court held it inapplicable because the complaints were real property actions under Section 19(2).
• Section 19(2), Batas Pambansa Blg. 129, as amended by Republic Act No. 7691 — Grants the RTC exclusive original jurisdiction in all civil actions involving title to, or possession of, real property, or any interest therein, where the assessed value of the property involved exceeds P20,000.00, or P50,000.00 in Metro Manila, except forcible entry and unlawful detainer. It also gives first-level courts jurisdiction where the assessed value does not exceed those amounts, exclusive of interest, damages, attorney's fees, litigation expenses, and costs. Applied: because the assessed values of the subject lots were less than P20,000.00, the MTC had jurisdiction; the value of trees cut could not be added to the assessed value.
• Section 44(b), Republic Act No. 296 (Judiciary Act of 1948), as amended — The forerunner of Section 19(2) of B.P. 129; it gave Courts of First Instance original jurisdiction over civil actions involving title to or possession of real property, or any interest therein, except forcible entry and detainer. Cited to explain the historical development of jurisdiction over real property actions.
• Section 48(b), Commonwealth Act No. 141, as amended by Republic Act No. 1942 — The Public Land Act provision under which petitioners claimed the subject lots as private property or as land to which they had acquired imperfect title. It formed the basis of petitioners' ownership claim but was not the basis of the jurisdictional ruling.
• Republic Act No. 7691 — An Act Expanding the Jurisdiction of the Metropolitan Trial Courts, Municipal Trial Courts, and Municipal Circuit Trial Courts, amending B.P. 129. It expanded first-level courts' jurisdiction over real property actions based on assessed value and was applied to hold that the MTC had jurisdiction.
• Section 1, Rule 65, Rules of Court — Petitioners argued that respondents' Court of Appeals petition should have been dismissed for failure to submit certified true copies of the assailed orders. The Court did not resolve this issue.
• Rule 45, Rules of Court — The appeal by certiorari under which the case reached the Supreme Court. Mentioned as the mode of review.

Ynares-Santiago, Sandoval-Gutierrez, Corona, and Azcuna, JJ., concur.