San Pedro vs. Trinidad

When the Regional Trial Court tries and decides a case originally filed before the Municipal Trial Court pursuant to Rule 40, Section 8 of the Rules of Court, it exercises appellate, not original, jurisdiction; consequently, the proper mode of appeal from such RTC decision to the Court of Appeals is by petition for review under Rule 42, not by a notice of appeal.

Spouses Angelito and Consuelo Trinidad filed a complaint for forcible entry against Reynaldo San Pedro and his cohorts before the MTC of Sta. Rosa, Nueva Ecija. They alleged ownership of a 188.80-square-meter parcel of land based on a Deed of Absolute Sale with Waiver of Rights (DOAS) executed by Reynaldo. They claimed that in April 2016, Reynaldo entered the property without permission through force, strategy, and stealth. Reynaldo, in his Answer, denied the spouses' prior physical possession and asserted his own continuous possession since time immemorial.

• Nature of the Action: The spouses Trinidad filed a forcible entry case against Reynaldo, claiming ownership and prior physical possession of a 188.80 sq.m. parcel of land, evidenced by a notarized Deed of Absolute Sale (DOAS) executed by Reynaldo.
• Alleged Dispossession: The spouses alleged that in April 2016, Reynaldo, with others, entered the property without permission using force, strategy, and stealth.
• Reynaldo's Defense: Reynaldo denied the spouses' prior possession, claimed continuous possession since time immemorial, and argued the DOAS actually evidenced a loan transaction, not a sale.
• MTC Ruling: The MTC dismissed the case, holding the spouses failed to prove prior physical possession, distinguishing it from ownership.
• RTC Proceedings: On appeal, the RTC determined the MTC lacked jurisdiction over the subject matter (as the assessed value of improvements exceeded the MTC's jurisdictional amount). Applying Rule 40, Section 8, the RTC tried the case anew. It rejected Reynaldo's loan claim for lack of evidence (e.g., no period of repayment or interest) and found the DOAS valid. Citing Article 1495 of the Civil Code, the RTC ruled Reynaldo failed to place the spouses in possession and ordered him to vacate.
• Procedural Misstep: Reynaldo appealed the RTC decision to the CA via a Notice of Appeal. The CA dismissed it, holding the proper mode was a Petition for Review under Rule 42 because the RTC had exercised appellate jurisdiction.

• Jurisdiction of the RTC: Petitioner argued that the RTC Decision was rendered in the exercise of its original jurisdiction because Rule 40, Section 8 directs the RTC to decide the case "as if the case was originally filed with it." Therefore, an ordinary appeal via notice of appeal was the correct mode.

• Appellate Jurisdiction: Respondents countered that the case reached the RTC only via appeal from the MTC. The RTC's act of taking cognizance and trying the case anew was pursuant to its appellate jurisdiction under Rule 40, Section 8, making a petition for review under Rule 42 the mandatory mode of appeal to the CA.

• Proper Mode of Appeal: Whether the Court of Appeals erred in dismissing the appeal for being a wrong mode, i.e., whether the RTC decision was rendered in the exercise of its appellate or original jurisdiction.

• Proper Mode of Appeal: The Court of Appeals did not err. The RTC's decision was rendered in the exercise of its appellate jurisdiction. The phrase "as if the case was originally filed with it" in Rule 40, Section 8 is a procedural mechanism for judicial economy and convenience; it does not convert the nature of the RTC's jurisdiction from appellate to original. The case originated in the MTC and reached the RTC solely through appeal. Consequently, under Rule 50, Section 2, an appeal by notice of appeal from an RTC's appellate judgment must be dismissed. The correct mode was a petition for review under Rule 42.

• Nature of RTC Jurisdiction under Rule 40, Sec. 8 — When an MTC tries a case on the merits without jurisdiction over the subject matter, and the RTC has original jurisdiction, the RTC shall not dismiss the case on appeal but shall decide it as if originally filed before it. This directive is for procedural efficiency and does not alter the RTC's exercise of appellate jurisdiction. The case remains an appealed case, and the proper mode of further appeal to the CA is by petition for review under Rule 42.

• "Consequently, the phrase in Rule 40, Section 8 that the RTC shall decide the case 'as if the same was originally filed before it' does not convert the type of jurisdiction being exercised by the RTC, which remains to be appellate. The phrase does not change the fact that the case was originally or first filed before the MTC and reached the RTC only via appeal."
• "Appeal is a mere statutory privilege and may be exercised only in accordance with law. A party who seeks to avail of the privilege must comply with the requirements of the rules lest the right to appeal is invariably lost."

• De Vera v. Spouses Santiago, 761 Phil. 90 (2015) — Cited as controlling precedent. The Court therein held that an RTC decision rendered under Rule 40, Section 8 is promulgated in the exercise of appellate jurisdiction, thereby affirming the CA's dismissal of an improper mode of appeal in the present case.
• Sugar Regulatory Administration v. Central Azucarera De Bais, Inc., G.R. No. 253821, March 6, 2023 — Cited for the principle that appeal is a statutory privilege that must be exercised in accordance with procedural rules.

• Rule 40, Section 8, Rules of Court — Provides that if a case was tried on the merits by the lower court without jurisdiction, the RTC on appeal shall not dismiss the case if it has original jurisdiction but shall decide it "as if the case was originally filed with it." The Court interpreted this provision.
• Rule 41, Section 2(b), Rules of Court — Specifies that the mode of appeal to the CA from an RTC decision rendered in the exercise of its appellate jurisdiction is by petition for review under Rule 42.
• Rule 50, Section 2, Rules of Court — Mandates the dismissal of an appeal by notice of appeal instead of by petition for review from an appellate judgment of the RTC.
• Article 1495, Civil Code — Cited by the RTC in its decision on the merits. It provides that the vendor is bound to transfer the ownership of and deliver the thing sold to the vendee, which includes placing the vendee in possession.

• Justice Caguioa (Chairperson)
• Justice Dimaampao
• Justice Singh (Justice Inting was on official business.)