Supapo vs. De Jesus

Jurisdiction over actions involving title to or possession of real property is determined by the property's assessed value as provided in RA 7691, and the right to recover possession of land registered under the Torrens System is imprescriptible.

The Spouses Supapo owned a registered lot in Novaliches, Quezon City. In 1992, they discovered respondents had built houses on it without consent. After a failed conciliation, they filed a criminal case for squatting (PD 772), which resulted in conviction. However, the law was later repealed (RA 8368), extinguishing the criminal liability and the civil liability arising from it. The Spouses Supapo then filed a civil action for accion publiciana to recover possession.

• Filed in MeTC of Caloocan City (Civil Case No. 08-29245).
• MeTC denied respondents' motion to dismiss based on affirmative defenses.
• Respondents filed a certiorari petition with the RTC.
• RTC granted the petition, dismissed the case for lack of jurisdiction (ruling accion publiciana belongs to RTC) and prescription.
• Spouses Supapo appealed to the CA.
• CA affirmed the RTC decision.
• Spouses Supapo elevated to the SC via Rule 45 petition.

• Petitioners hold TCT No. C-28441 over the subject lot (assessed value P39,980.00 in Metro Manila).
• Respondents occupied the lot and built houses without permission since 1992.
• A prior criminal case under PD 772 (Anti-Squatting Law) ended with conviction, but the law was repealed, extinguishing liabilities.
• Petitioners filed accion publiciana on March 7, 2008.
• Respondents argued prescription (10-year period under Art. 555 Civil Code) and res judicata from the criminal case.

• The MeTC has jurisdiction because the assessed value (P39,980.00) is below P50,000.00 for Metro Manila properties under RA 7691.
• Their cause of action is imprescriptible because the land is registered under the Torrens System (PD 1529, Sec. 47).
• The prior criminal case does not bar the civil action under res judicata due to lack of identity of parties, subject matter, and cause of action.

• The accion publiciana should have been filed with the RTC, not the MeTC.
• The action is barred by prescription under Article 555 of the Civil Code (10-year period to recover possession).
• The action is barred by res judicata due to the final judgment in the criminal case.

• Procedural Issues: N/A
• Substantive Issues:
  1. Whether the MeTC properly acquired jurisdiction over the accion publiciana.
  2. Whether the cause of action has prescribed.
  3. Whether the complaint is barred by res judicata.

• Procedural: N/A
• Substantive:
  1. Yes. Jurisdiction is determined by the assessed value of the property. Under RA 7691, MeTCs have exclusive original jurisdiction where the assessed value does not exceed P50,000.00 in Metro Manila. The complaint alleged and proved an assessed value of P39,980.00.
  2. No. Lands registered under the Torrens System cannot be acquired by prescription or adverse possession (PD 1529, Sec. 47). The registered owner's right to recover possession is imprescriptible.
  3. No. Res judicata (both bar by prior judgment and conclusiveness of judgment) does not apply because there is no identity of parties, subject matter, or cause of action between the criminal case (prosecuted by the People) and the civil accion publiciana (filed by the private owners).

• Jurisdiction Based on Assessed Value (RA 7691) — Amended BP 129 to grant MeTCs, MTCs, and MCTCs exclusive original jurisdiction over civil actions involving title to or possession of real property where the assessed value does not exceed P20,000.00 (outside Metro Manila) or P50,000.00 (in Metro Manila). The SC applied this by looking at the tax declaration showing an assessed value of P39,980.00.
• Imprescriptibility of Registered Land (Torrens System) — Under PD 1529 (Property Registration Decree), Section 47, no title to registered land shall be acquired by prescription or adverse possession. The SC held this applies to the right to recover possession, making it imprescriptible.
• Accion Publiciana — An action for recovery of the right to possess, filed after the lapse of one year from the accrual of the cause of action (unlike ejectment). The SC clarified that while its objective is to recover possession only, courts may pass upon ownership provisionally to resolve possession.
• Res Judicata — The SC applied the four-fold test for bar by prior judgment: (1) final judgment, (2) judgment on the merits, (3) jurisdiction, and (4) identity of parties, subject matter, and cause of action. It found the fourth element lacking.

• "The Government has adopted the Torrens system due to its being the most effective measure to guarantee the integrity of land titles and to protect their indefeasibility once the claim of ownership is established and recognized." — Emphasizes the policy behind the Torrens System's imprescriptibility.
• "The adjudication of the issue of ownership, being provisional, is not a bar to an action between the same parties involving title to the property." — Clarifies the limited nature of ownership determination in accion publiciana.

• Quinagoran v. Court of Appeals — Cited to overturn the old doctrine that all accion publiciana cases fall under RTC jurisdiction regardless of property value; now jurisdiction depends on assessed value.
• Bishop v. Court of Appeals — Cited for the rule that a registered owner's right to recover possession is imprescriptible, regardless of the length of unauthorized possession.
• Umpoc v. Mercado — Cited to illustrate that a TCT prevails over an unregistered deed of sale, reinforcing the indefeasibility of the Torrens title.
• Vda. de Aguilar v. Alfaro — Cited to define accion publiciana and explain that ownership may be looked into only to determine possession.

• Republic Act No. 7691 (1994) — Amended BP 129 to expand jurisdiction of inferior courts based on assessed value of real property.
• Presidential Decree No. 1529 (1978), Section 47 — Provides that registered land is not subject to prescription or adverse possession.
• Article 555 of the Civil Code — Invoked by respondents on prescription; the SC distinguished it by applying the Torrens System rule.
• Rule 39, Section 47(b) and (c) of the Rules of Court — Defines res judicata (bar by prior judgment and conclusiveness of judgment).