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    Quinagoran V CA Gr155179

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    Adi Lim
    The Supreme Court ruled that the RTC does not have exclusive jurisdiction over all cases involving recovery of possession of real property regardless of value. Under RA 7691, if the assessed value of the property is below P20,000 for areas outside Metro Manila or P50,000 for Metro Manila, the MTC has jurisdiction. Since the complaint did not establish that the assessed value of the disputed land exceeded these amounts, the MTC, not the RTC, had proper jurisdiction over the case.

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    Quinagoran V CA Gr155179

    Uploaded by

    Adi Lim
    81 views2 pages
    The Supreme Court ruled that the RTC does not have exclusive jurisdiction over all cases involving recovery of possession of real property regardless of value. Under RA 7691, if the assessed value of the property is below P20,000 for areas outside Metro Manila or P50,000 for Metro Manila, the MTC has jurisdiction. Since the complaint did not establish that the assessed value of the disputed land exceeded these amounts, the MTC, not the RTC, had proper jurisdiction over the case.

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    Quinagoran v CA Gr155179

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    The Supreme Court ruled that the RTC does not have exclusive jurisdiction over all cases involving recovery of possession of real property regardless of value. Under RA 7691, if the assessed value of the property is below P20,000 for areas outside Metro Manila or P50,000 for Metro Manila, the MTC has jurisdiction. Since the complaint did not establish that the assessed value of the disputed land exceeded these amounts, the MTC, not the RTC, had proper jurisdiction over the case.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    81 views2 pages

    Quinagoran V CA Gr155179

    Uploaded by

    Adi Lim
    The Supreme Court ruled that the RTC does not have exclusive jurisdiction over all cases involving recovery of possession of real property regardless of value. Under RA 7691, if the assessed value of the property is below P20,000 for areas outside Metro Manila or P50,000 for Metro Manila, the MTC has jurisdiction. Since the complaint did not establish that the assessed value of the disputed land exceeded these amounts, the MTC, not the RTC, had proper jurisdiction over the case.

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    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
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    VICTORINO QUINAGORAN, Petitioner, vs.

    COURT OF
    APPEALS and THE HEIRS OF JUAN DE LA CRUZ,
    Respondents.
    G.R. NO. 155179 August 24, 2007
    AUSTRIA-MARTINEZ, J.:

    FACTS:

    The heirs of Juan dela Cruz filed a complaint for recovery of


    a parcel of land with damages before RTC of Cagayan
    against Quinagoran.

    Quinagoran filed a Motion to Dismiss claiming that the RTC


    has no jurisdiction over the case under R.A. No. 7691, which
    expanded the exclusive original jurisdiction of the MTC to
    include all civil actions which involve title to, or possession
    of, real property, or any interest therein which does not
    exceed P20,000.00. He argued that since the 346 sq m lot
    which he owns adjacent to the contested property has an
    assessed value of P1,730, the assessed value of the lot
    under controversy would not be more than the said amount.

    The RTC denied petitioner's Motion to Dismiss on the basis


    that the action is accion publicciana and therefore, its
    jurisdiction lies in the RTC, regardless of the value of the
    property. The CA affirmed decision of the RTC.

    Petitioner appealed to the Supreme Court claiming that


    under RA 7691, the jurisdiction falls in the MTC. He likewise
    avers that it is an indispensable requirement that the
    complaint should allege the assessed value of the property
    involved. The complaint does not alleged that the assessed
    value of the land in question is more than P20,000.00. There
    was also no tax declaration attached to the complaint to
    show the assessed value of the property. Respondents,
    therefore, failed to alleged that the RTC has jurisdiction over
    the case.

    ISSUE:

    Whether or not the RTC has jurisdiction over all cases of


    recovery of possession regardless of the value of the
    property involved
    RULING:

    No. The doctrine that all cases of recovery of possession or


    accion publiciana lies with the RTC regardless of the value of
    the property -- no longer holds true. As things now stand, a
    distinction must be made between those properties the
    assessed value of which is below P20,000.00, if outside
    Metro Manila; and P50,000.00, if within.

    Republic Act No. 7691 expressly provides:

    SEC. 19. Jurisdiction in civil cases – Regional Trial Courts


    shall exercise exclusive original jurisdiction:

    (2) In all civil actions which involve the title to or possession


    of, real property, or any interest therein, where the assessed
    value of the property involved exceeds Twenty thousand
    pesos (P20,000.00) or, for civil actions in Metro Manila,
    where such value exceeds Fifty thousand pesos
    (P50,000.00) except for forcible entry into and unlawful
    detainer of lands or buildings, original jurisdiction over which
    is conferred upon the Metropolitan Trial Courts, Municipal
    Trial Courts, and Municipal Circuit Trial Courts.

    In Atuel v. Valdez (G.R. No. 139561, June 10, 2003, 403


    SCRA 517), the Court likewise expressly stated that:
    Jurisdiction over an accion publiciana is vested in a court of
    general jurisdiction. Specifically, the regional trial court
    exercises exclusive original jurisdiction “in all civil actions
    which involve x x x possession of real property.” However, if
    the assessed value of the real property involved does not
    exceed P50,000.00 in Metro Manila, and P20,000.00 outside
    of Metro Manila, the municipal trial court exercises
    jurisdiction over actions to recover possession of real
    property.

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