CaseDig: Padlan vs. Dinglasan

Posted by: Ana R. Bonita on July 27, 2018



FACTS:


  • Elenita Dinglasan (Elenita)  was the registered owner of a parcel of land with an aggregate area of 82,972 square meters.
  • One Maura Passion (Maura) got the owner's copy of the CTC from Elenita.
  • Maura then subdivided the property into several lots, under the name of Elenita and her husband Felicisimo, without their knowledge and consent through fraudulent manipulations.
  • Through a falsified deed of sale bearing the forged signature of Elenita and her husband Felicisimo, Maura was able to sell the lots to different buyers.
  • One of the lots - Lot No. 625-K was sold to one Lorna Ong (Lorna), who later caused the issuance of TCT No. 134932 for the subject property under her name.
  • A few months later, Lorna sold the lot to petitioner Editha Padlan for ₱4,000.00. Thus, TCT No. 134932 was cancelled and TCT No. 137466 was issued in the name of petitioner.
  • After learning what had happened, Sps. Elenita and Felicisimo demanded petitioner to surrender possession of Lot No. 625-K, but the latter refused.
  • Sps. Elenita and Felicisimo were then forced to file a case before the Regional Trial Court (RTC) for the Cancellation of Transfer Certificate of Title No. 137466.
  • Summons was, thereafter, served to Editha Padlan, who was residing in Japan, through her mother, Anita Padlan.

 ISSUES:
  1. Whether or not the RTC has jurisdiction over the subject matter of the case.
  2. Whether or not the RTC has jurisdiction over the person of the petitioner.

HELD:
  • What determines the jurisdiction of the court is the nature of the action pleaded as appearing from the allegations in the complaint. The averments therein and the character of the relief sought are the ones to be consulted.
  • An action "involving title to real property" means that the plaintiff's cause of action is based on a claim that he owns such property or that he has the legal rights to have exclusive control, possession, enjoyment, or disposition of the same. Title is the "legal link between (1) a person who owns property and (2) the property itself."
  • "Title" is different from a "certificate of title" which is the document of ownership under the Torrens system of registration issued by the government through the Register of Deeds. While title is the claim, right or interest in real property, a certificate of title is the evidence of such claim.
  • In the present controversy, before the relief prayed for by the respondents in their complaint can be granted, the issue of who between the two contending parties has the valid title to the subject lot must first be determined before a determination of who between them is legally entitled to the certificate of title covering the property in question.
  • From the Complaint, the case filed by respondent is not simply a case for the cancellation of a particular certificate of title and the revival of another. The determination of such issue merely follows after a court of competent jurisdiction shall have first resolved the matter of who between the conflicting parties is the lawful owner of the subject property and ultimately entitled to its possession and enjoyment.
  • The action is, therefore, about ascertaining which of these parties is the lawful owner of the subject lot, jurisdiction over which is determined by the assessed value of such lot.
  • In no uncertain terms, the Court has already held that a complaint must allege the assessed value of the real property subject of the complaint or the interest thereon to determine which court has jurisdiction over the action.
  • In the case at bar, the only basis of valuation of the subject property is the value alleged in the complaint that the lot was sold by Lorna to petitioner in the amount of ₱4,000.00. No tax declaration was even presented that would show the valuation of the subject property.
  • To reiterate, where the ultimate objective of the plaintiffs is to obtain title to real property, it should be filed in the proper court having jurisdiction over the assessed value of the property subject thereof.
  • Since the amount alleged in the Complaint by respondents for the disputed lot is only ₱4,000.00, the MTC and not the RTC has jurisdiction over the action.
  • Therefore, all proceedings in the RTC are null and void.
  • Consequently, the remaining issues raised by petitioner need not be discussed further.
  • WHEREFORE, the petition is GRANTED. The Decision of the Court of Appeals and its Resolution are REVERSED and SET ASIDE. The Decision of the Regional Trial Court is declared NULL and VOID. The complaint before the RTC is dismissed without prejudice.