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Foronda-Crystal V Son

This document summarizes a Supreme Court of the Philippines decision regarding a land dispute. It describes how the respondent filed a case in the regional trial court claiming ownership of a parcel of land despite the petitioner's father holding the original land title. The court discusses the issues of whether the trial court had proper jurisdiction, whether the original title should be canceled, and whether the case was barred by prescription. The court found the petition had merit and that issues regarding the trial court's jurisdiction and validity of canceling the original title needed to be addressed.

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0% found this document useful (0 votes)
125 views10 pages

Foronda-Crystal V Son

This document summarizes a Supreme Court of the Philippines decision regarding a land dispute. It describes how the respondent filed a case in the regional trial court claiming ownership of a parcel of land despite the petitioner's father holding the original land title. The court discusses the issues of whether the trial court had proper jurisdiction, whether the original title should be canceled, and whether the case was barred by prescription. The court found the petition had merit and that issues regarding the trial court's jurisdiction and validity of canceling the original title needed to be addressed.

Uploaded by

Lui Sebastian
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as PDF, TXT or read online on Scribd
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SECOND DIVISION

[G.R. No. 221815. November 29, 2017.]

GLYNNA FORONDA-CRYSTAL , petitioner, vs. ANIANA LAWAS SON ,


respondent.

DECISION

REYES, JR. , J : p

In law, nothing is as elementary as the concept of jurisdiction, for the same is the
foundation upon which the courts exercise their power of adjudication, and without
which, no rights or obligation could emanate from any decision or resolution.

The Case

Challenged before this Court via this Petition for Review on Certiorari under Rule
45 of the Rules of Court is the Decision 1 of the Court of Appeals (CA) in CA-G.R. CV No.
02226 promulgated on March 12, 2015, which a rmed in toto the Decision 2 dated
November 24, 2006 of the Regional Trial Court (RTC), Branch 55 of Mandaue City.
Likewise challenged is the subsequent Resolution 3 promulgated on October 19, 2015
which upheld the earlier decision.

The Antecedent Facts

Petitioner is the daughter of Eddie Foronda, the registered owner of a parcel of


land located in Barrio Magay, Municipality of Compostela, Province of Cebu. The latter
derived his title over the property from a successful grant of a Free Patent (Free Patent
No. VII-519533), which is covered by Original Certi cate of Title (OCT) No. OP-37324,
more particularly described as follows: ATICcS

A PARCEL OF LAND (lot 1280, Case 3, Pls .962) situated in the Barrio of
Magay, Municipality of Compostela, Province of Cebu, Island of Cebu. Bounded
on the SE., along line 1-2 by Lot 707 (As 07-01-000033-amended); along line 2-3
by Lot 1275; on the SW., along line 3-4 by Lot 1281; on the NW., along line 4-5 by
Lot 1315; along line 5-6 by Lot 1314; on the NE., along line 6-7 by Lot 1392,
along line 7-1 by Lot 1279, all of Compostela, Cadastre x x x. 4
On March 15, 1999, Aniana Lawas Son (respondent) instituted an action for
reconveyance and damages against Glynna Foronda-Crystal (petitioner) alleging that,
for twelve and a half years, she has been the lawful owner and possessor of the subject
lot. She alleged that she purchased the same from a certain Eleno T. Arias (Arias) on
August 4, 1986 for a sum of P200,000.00. According to her, since her acquisition, she
has been religiously paying real property taxes thereon as evidenced by Tax Declaration
No. 16408A, which was issued under her name. 5
According to the respondent, the issuance of the Free Patent in favor of the
petitioner's father was "due to gross error or any other cause." 6 In support thereof, the
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respondent alleged that "there is no tax declaration in the name of patentee Eddie
Foronda" and that this "goes to show that Eddie Foronda is not the owner of lot 1280
and neither has payment of real estate taxes been made by him when he was still alive
or by his heirs." 7
On April 13, 1999, herein petitioner led a motion to dismiss on the grounds of
(1) lack of jurisdiction, (2) venue is improperly laid, (3) action has prescribed, and, (4)
lack of cause of action. A week thereafter, the RTC issued an Order dated April 20,
1999, 8 which dismissed the case for lack of jurisdiction. The RTC asserted that the
"market value of the subject property per Tax Declaration No. 16408 (Annex B,
Complaint) is P2,830.00" and thus, jurisdiction over the case lies with the Municipal
Circuit Trial Court of Liloan-Compostela, Cebu.
However, in yet another Order 9 dated July 23, 1999, issued by the RTC following
herein respondent's motion for reconsideration, the RTC reconsidered and set aside its
earlier ruling based on the following ratiocination: (1) Paragraph III of the Complaint
stated that the property was worth P200,000.00; (2) the Court has "judicial knowledge
that under the BIR zonal valuation, the property located at Magay, Compostela, Cebu
carries the value that may summed (sic) up to more than P20,000.00 for the property
with an area of 1,570 square meters"; 1 0 and (3) the "tax declaration, sometimes being
undervalued, is not controlling." 1 1 Hence, trial ensued.
On November 24, 2006, the RTC rendered its Decision in favor of the respondent.
The Register of Deeds of Cebu was ordered to cancel OCT No. OP-37324, and to issue,
in lieu thereof, a new one under the name of the respondent. The dispositive portion of
the decision reads:
WHEREFORE, premises considered, judgment in favor of the plaintiff and
against the defendants:
1) Declaring the issuance of Original Certi cate of Title No. OP-
37324 (Free Patent No. VII-519533) in the name of Eddie Foronda a grave error
since he is not the owner of Lot 1280, and therefore null and void;
2) Ordering the Register of Deeds of Cebu to cancel Original
Certi cate of Title No. OP-37324 (Free Patent No. VII-519533) and to issue, in
lieu thereof, a new one in the name of Aniana Lawas Son of Compostela, Cebu.
No pronouncement as to damages and costs of the suit.
SO ORDERED. 1 2
Aggrieved, petitioner herein elevated the case to the CA. The material allegations
that she presented included the following: (1) the RTC rendered its decision with undue
haste considering that the same was promulgated even before the expiration of the
period within which the parties' respective memoranda were to be led; (2) the
respondent was not able to prove that the lot she acquired from Arias was Lot No.
1280; (3) the respondent failed to prove that she was in actual physical possession of
the subject property whereas the petitioner was able to do so since 1972; (4) the RTC
erred in its order to cancel OCT No. OP-37324 and to issue, in lieu thereof, a new title in
herein respondent's name; and (5) the action led by the respondent was already
barred by prescription and laches.
On March 12, 2015, the CA rendered the assailed Decision, which a rmed the
RTC decision. The fallo of CA decision reads:
WHEREFORE, premises considered, the instant appeal is DENIED. The
Decision of the Regional Trial Court, Branch 55, Mandaue City dated November
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24, 2006 in Civil Case No. MAN-3498, is hereby AFFIRMED.
SO ORDERED. 1 3
On October 19, 2015, the Resolution 1 4 issued by the CA denied the petitioner's
motion for reconsideration. Hence, this petition for review on certiorari under Rule 45 of
the Rules of Court.

The Issues

The petitioner anchors her plea for the reversal of the assailed decision on the
following grounds: 1 5
I. THE COURT OF APPEALS ERRED IN NOT DISMISSING THIS CASE ON THE
GROUND OF LACK OF JURISDICTION OF THE RTC OF MANDAUE CITY
OVER THIS CASE AS THE ASSESSED VALUE OF THE PROPERTY SUBJECT
OF THIS CASE IS P1,030.00 AND THE PROPERTY IS LOCATED IN
COMPOSTELA, CEBU.
II. THE COURT OF APPEALS ERRED IN NOT DECLARING THE PROCEEDINGS
AS WELL AS THE JUDGMENT RENDERED BY THE RTC AS VOID.
III. THE COURT OF APPEALS ERRED IN NOT APPLYING ARTICLE 434 OF THE
CIVIL CODE TO THE CASE AT BAR.
IV. THE COURT OF APPEALS ERRED IN NOT HOLDING THAT LOT NO. 1280
WAS A PUBLIC GRANT TO WHICH EDDIE FORONDA WAS ISSUED A FREE
PATENT.
V. THE COURT OF APPEALS ERRED IN NOT HOLDING THAT THE ACTION IS
BARRED BY PRESCRIPTION.
VI. THE COURT OF APPEALS ERRED IN NOT HOLDING THAT THE ACTION IS
BARRED BY PRESCRIPTION (SIC).
VII. THE COURT OF APPEALS ERRED IN NOT HOLDING THAT THE VALIDITY
AND INTEGRITY OF THE DECISION OF THE RTC IS QUESTIONABLE
BECAUSE IT WAS RENDERED WITH UNDUE HASTE.
The foregoing assignment of errors could be summarized in three main issues:
(1) whether or not the RTC validly acquired jurisdiction over the case, and whether or
not the RTC decision was void ab initio; (2) whether or not the Original Certi cate of
Title issued under the name of petitioner's father should be canceled and set aside on
the strength of the respondent's allegations of ownership over the same; and (3)
whether or not the action is already barred by prescription.

The Court's Ruling

The petition is impressed with merit.


On the Issue of Jurisdiction
Jurisdiction is de ned as the power and authority of a court to hear, try, and
decide a case. 1 6 In order for the court or an adjudicative body to have authority to
dispose of the case on the merits, it must acquire, among others, jurisdiction over the
subject matter. 1 7 It is axiomatic that jurisdiction over the subject matter is the power
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to hear and determine the general class to which the proceedings in question belong; it
is conferred by law and not by the consent or acquiescence of any or all of the parties
or by erroneous belief of the court that it exists. 1 8
What is relevant in this case, therefore, is the delineation provided for by law
which separates the jurisdictions of the second level courts — the Regional Trial Courts
— and the rst level courts — the Metropolitan Trial Courts (MeTC), Municipal Trial
Courts (MTC), Municipal Circuit Trial Courts (MCTC), and Municipal Trial Courts in the
Cities (MTCC). cSEDTC

This can be easily ascertained through a reading of the Judiciary Reorganization


Act of 1980, as amended by Republic Act No. 7691. 1 9
According to this law, in all civil actions which involve title to, or possession of,
real property, or any interest therein, the RTC shall exercise exclusive original
jurisdiction where the assessed value of the property exceeds P20,000.00 or, for civil
actions in Metro Manila, where such value exceeds P50,000.00. 2 0 For those below the
foregoing threshold amounts, exclusive jurisdiction lies with the MeTC, MTC, MCTC, or
MTCC. 2 1
For a full discourse on the resolution of the present petition, emphasis must be
given on the assessed values 2 2 — not the fair market values — of the real properties
concerned.
According to the case of Heirs of Concha, Sr. v. Spouses Lumocso , 2 3 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. Heirs of Concha, Sr. averred this
de nitive ruling by tracing the history of the The Judiciary Reorganization Act of 1980,
as amended. It said:
The original text of Section 19(2) of B.P. 129 as well as its forerunner,
Section 44(b) of R.A. 296, as amended, gave the RTCs x x x exclusive original
jurisdiction. x x x Thus, under the old law, there was no substantial effect on
jurisdiction whether a case is one, the subject matter of which was incapable of
pecuniary estimation, under Section 19(1) of B.P. 129 or one involving title to
property under Section 19(2).
The distinction between the two classes became crucial with the
amendment introduced by R.A. No. 7691 in 1994 which expanded the exclusive
original jurisdiction of the rst level courts. x x x. Thus, under the present law,
original jurisdiction over cases the subject matter of which involves "title to,
possession of, real property or any interest therein" under Section 19(2) of B.P.
129 is divided between the rst 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 which would
result in the speedier administration of justice." 2 4 (Emphasis, underscoring and
formatting supplied, citations omitted)AIDSTE

Time and again, this Court has continuously upheld Heirs of Concha, Sr.'s ruling
on this provision of law. 2 5 In fact, in Malana, et al. v. Tappa, et al . 2 6 the Court said that
"the Judiciary Reorganization Act of 1980, as amended, uses the word 'shall' and
explicitly requires the MTC to exercise exclusive original jurisdiction over all civil actions
which involve title to or possession of real property where the assessed value does not
exceed P20,000.00." 2 7
To determine the assessed value, which would in turn determine the court with
appropriate jurisdiction, an examination of the allegations in the complaint is necessary.
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It is a hornbook doctrine that the court should only look into the facts alleged in the
complaint to determine whether a suit is within its jurisdiction. 2 8 According to the case
o f Spouses Cruz v. Spouses Cruz, et al. , 2 9 only these facts can be the basis of the
court's competence to take cognizance of a case, and that one cannot advert to
anything not set forth in the complaint, such as evidence adduced at the trial, to
determine the nature of the action thereby initiated. 3 0
It is not a surprise, therefore, that a failure to allege the assessed value of a real
property in the complaint would result to a dismissal of the case. This is because
absent any allegation in the complaint of the assessed value of the property, it cannot
be determined whether the RTC or the MTC has original and exclusive jurisdiction over
the petitioner's action. Indeed, the courts cannot take judicial notice of the assessed or
market value of the land. 3 1 This is the same ratio put forth by the Court in the case of
Spouses Cruz v. Spouses Cruz, et al. , 3 2 where the case was dismissed partly on the
basis of the following:
The complaint did not contain any such allegation on the assessed value
of the property. There is no showing on the face of the complaint that the RTC
had jurisdiction over the action of petitioners. Indeed, absent any allegation in
the complaint of the assessed value of the property, it cannot be determined
whether it is the RTC or the MTC which has original and exclusive jurisdiction
over the petitioners' action. 3 3 (Citations omitted)
In Quinagoran v. Court of Appeals , 3 4 the Court had no qualms in dismissing the
case for failing to allege the assessed value of the subject property. Similar to Spouses
Cruz, 3 5 Quinagoran 3 6 held that: "Considering that the respondents failed to allege in
their complaint the assessed value of the subject property, the RTC seriously erred in
denying the motion to dismiss. Consequently, all proceedings in the RTC are null and
void, and the CA erred in affirming the RTC."
This is not to say, however, that there is no room for a liberal interpretation of this
rule. In Tumpag v. Tumpag , 3 7 the Court, through Justice Brion, provided for an instance
when an exception to the strict application could be allowed. It said:
Generally, the court should only look into the facts alleged in the
complaint to determine whether a suit is within its jurisdiction. There may be
instances, however, when a rigid application of this rule may result in defeating
substantial justice or in prejudice to a party's substantial right. 3 8
In that case, there was also no allegation of the assessed value of the property.
However, the Court pointed out that the facts contained in the Declaration of Real
Property, which was attached to the complaint, could have facially resolved the
question on jurisdiction and would have rendered the lengthy litigation on that very
point unnecessary. 3 9 In essence, the Court said that the failure to allege the real
property's assessed value in the complaint would not be fatal if, in the documents
annexed to the complaint, an allegation of the assessed value could be found.
A reading of the quoted cases would reveal a pattern which would invariably
guide both the bench and the bar in similar situations. Based on the foregoing, the rule
on determining the assessed value of a real property, insofar as the identi cation of the
jurisdiction of the first and second level courts is concerned, would be two-tiered: SDAaTC

First, the general rule is that jurisdiction is determined by the assessed


value of the real property as alleged in the complaint; and
Second, the rule would be liberally applied if the assessed value of the
property, while not alleged in the complaint, could still be identi ed through a
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facial examination of the documents already attached to the complaint.
Indeed, it is by adopting this two-tiered rule that the Court could dispense with a
catena of cases speci cally dealing with issues concerning jurisdiction over real
properties.
In upholding these afore-quoted rule, however, the Court is not unmindful of the
cases of Barangay Piapi v. Talip 4 0 and Trayvilla v. Sejas 4 1 where the market value of
the property, instead of the assessed value thereof, was used by the Court as basis for
determining jurisdiction.
I n Barangay Piapi, 4 2 the complaint did not allege the assessed value of the
subject property. What it alleged was the market value thereof. The Court held that, in
the absence of an allegation of assessed value in the complaint, the Court shall
consider the alleged market value to determine jurisdiction.
Notably, this case referred to Section 7 (b), Rule 141 of the Rules of Court, which
deals with Legal Fees, to justify its reliance on the market value. It said:
The Rule requires that " the assessed value of the property, or if
there is none, the estimated value thereof , shall be alleged by the
claimant." It bears reiterating that what determines jurisdiction is the
allegations in the complaint and the reliefs prayed for. Petitioners' complaint is
for reconveyance of a parcel of land. Considering that their action involves the
title to or interest in real property, they should have alleged therein its assessed
value. However, they only speci ed the market value or estimated value, which
is P15,000.00. Pursuant to the provision of Section 33 (3) quoted earlier, it is the
Municipal Circuit Trial Court of Padada-Kiblawan, Davao del Sur, not the RTC,
which has jurisdiction over the case. 4 3 (Italics in the original, and emphasis
supplied, citations omitted)
However, the rule alluded to above, while originally containing the sentence: "In a
real action, the assessed value of the property, or if there is none, the estimated value
thereof shall be alleged by the claimant and shall be the basis in computing the fees,"
has already been deleted through an amendment by A.M. No. 04-2-04-SC. As it currently
stands, Section 7 of Rule 141 of the Rules of Court reads:
Section 7. Clerks of Regional Trial Courts. —
a) For ling an action or a permissive OR COMPULSORY counter-
claim, CROSS-CLAIM, or money claim against an estate not based on judgment,
or for ling a third-party, fourth-party, etc. complaint, or a complaint-in-
intervention, if the total sum claimed, INCLUSIVE OF INTERESTS, PENALTIES,
SURCHARGES, DAMAGES OF WHATEVER KIND, AND ATTORNEY'S FEES,
LITIGATION EXPENSES AND COSTS and/or in cases involving property, the
FAIR MARKET value of the REAL property in litigation STATED IN THE
CURRENT TAX DECLARATION OR CURRENT ZONAL VALUATION OF THE
BUREAU OF INTERNAL REVENUE, WHICHEVER IS HIGHER, OR IF THERE IS
NONE, THE STATED VALUE OF THE PROPERTY IN LITIGATION OR THE VALUE
OF THE PERSONAL PROPERTY IN LITIGATION AS ALLEGED BY THE
CLAIMANT, is: x x x (Emphasis and underscoring supplied)
Two things must be said of this: rst, Rule 141 of the Rules of Court concerns the
amount of the prescribed ling and docket fees, the payment of which bestows upon
the courts the jurisdiction to entertain the pleadings to be led; 4 4 and second, the
latest iteration of the same provision already deleted the phrase "estimated value
thereof," such that the determination of the amount of prescribed ling and docket fees
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are now based on the following: (a) the fair market value of the real property in litigation
stated in the current tax declaration or current zonal valuation of the Bureau of Internal
Revenue; or (b) the stated value of the real or personal property in litigation as alleged
by the claimant.
A reading of the discourse on this would indicate that the jurisdiction referred to
above does not deal with the delineation of the jurisdictions of the rst and second
level courts, but with the acquisition of jurisdiction by the courts through the payment
of the prescribed filing and docket fees.
This is the same tenor of the Court's decision in Trayvilla. In that case, where no
assessed value was likewise alleged in the complaint, the Court determined jurisdiction
by considering the actual amount by which the property was purchased and as written
in the Amended Complaint. The Court stated that:
However, the CA failed to consider that in determining jurisdiction, it
could rely on the declaration made in the Amended Complaint that the property
is valued at P6,000.00. The handwritten document sued upon and the
pleadings indicate that the property was purchased by petitioners for
the price of P6,000.00. For purposes of ling the civil case against
respondents, this amount should be the stated value of the property in
the absence of a current tax declaration or zonal valuation of the BIR. 4 5
(Emphasis supplied)
But then again, like the discussion on Barangay Piapi above, Trayvilla was one
which dealt with the payment of the required ling and docket fees. The crux of the
case was the acquisition of jurisdiction by payment of docket fees, and not the
delineation of the jurisdiction of the rst and second level courts. In fact, Trayvilla
interchangeably used the terms "assessed value" and "market value" in a manner
that does not even recognize a difference.
Like Barangay Piapi, therefore, Spouses Trayvilla must not be read in the context
of jurisdiction of rst and second level courts as contemplated in the Judiciary
Reorganization Act of 1980, as amended, 4 6 where the assessed values of the
properties are required. These cases must perforce be read in the context of the
determination of the actual amount of prescribed ling and docket fees provided for in
Rule 141 of the Rules of Court. acEHCD

Having laid out the essential rules in determining the jurisdiction of the rst and
second level courts for civil actions which involve title to, or possession of, real
property, or any interest therein, the Court now shifts focus to the speci c
circumstances that surround the current case.
In here, the respondent failed to allege in her complaint the assessed value of the
subject property. Rather, what she included therein was an allegation of its market value
amounting to P200,000.00. 4 7 In the course of the trial, the petitioner asserted that the
assessed value of the property as stated in the tax declaration was merely P1,030.00,
and therefore the RTC lacked jurisdiction.
The question thus posed before this Court was whether or not the RTC should
have dismissed the case for lack of jurisdiction, and in the a rmative, whether or not
the RTC decision should be rendered void for being issued without jurisdiction.
As discussed above, settled is the requirement that the Judiciary Reorganization
Act of 1980, as amended, required the allegation of the real property's assessed value
in the complaint. That the complaint in the present case did not aver the assessed value
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of the property is a violation of the law, and generally would be dismissed because the
court which would exercise jurisdiction over the case could not be identified.
However, a liberal interpretation of this law, as opined by the Court in Tumpag , 4 8
would necessitate an examination of the documents annexed to the complaint. In this
instance, the complaint referred to Tax Declaration No. 16408A, attached therein as
Annex "B," which naturally would contain the assessed value of the property. A perusal
thereof would reveal that the property was valued at P2,826.00.
On this basis, it is clear that it is the MTC, and not the RTC, that has jurisdiction
over the case. The RTC should have upheld its Order dated November 8, 2006 which
dismissed the same. Consequently, the decision that it rendered is null and void.
In the case of Maslag v. Monzon , 4 9 the Court had occasion to rule that an order
issued by a court declaring that it has original and exclusive jurisdiction over the subject
matter of the case when under the law it has none cannot likewise be given effect. It
amounts to usurpation of jurisdiction which cannot be countenanced. Since the
Judiciary Reorganization Act of 1980, as amended, already apportioned the jurisdiction
of the MTC and the RTC in cases involving title to property, neither the courts nor the
petitioner could alter or disregard the same.
In yet another case, Diona v. Balangue , 5 0 the Court ruled that void judgment for
want of jurisdiction is no judgment at all. It cannot be the source of any right nor the
creator of any obligation. No legal rights can emanate from a resolution that is null and
void. As said by the Court in Cañero v. University of the Philippines: 5 1
A void judgment is not entitled to the respect accorded to a valid
judgment, but may be entirely disregarded or declared inoperative by any
tribunal in which effect is sought to be given to it. It has no legal or binding
effect or e cacy for any purpose or at any place. It cannot affect, impair or
create rights. It is not entitled to enforcement and is, ordinarily, no protection to
those who seek to enforce. In other words, a void judgment is regarded as a
nullity, and the situation is the same as it would be if there was no judgment. 5 2
Thus, considering the foregoing, it would be proper for the Court to immediately
dismiss this case without prejudice to the parties' ling of a new one before the MTC
that has jurisdiction over the subject property. Consequently, the other issues raised by
the petitioner need not be discussed further.
WHEREFORE , premises considered, the assailed Decision in CA-G.R. CV No.
02226 dated March 12, 2015, and the Resolution dated October 19, 2015 of the Court
of Appeals, as well as the Decision dated November 24, 2006 of the Regional Trial
Court, Branch 55 of Mandaue City, are hereby ANNULLED and SET ASIDE for being
issued without jurisdiction. This is without prejudice to the ling of the parties of the
proper action before the proper court. SDHTEC

SO ORDERED.
Carpio, Peralta, Perlas-Bernabe and Caguioa, JJ., concur.
Footnotes

1. Penned by Associate Justice Jhosep Y. Lopez, and concurred in by Associate Justice Gabriel
T. Ingles and Associate Justice Marilyn B. Lagura-Yap; rollo, pp. 52-79.

2. Id. at 125-128.
3. Id. at 88-92.
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4. Id. at 53.
5. Id. at 103-104.
6. Id.

7. Id. at 104-105.
8. Id. at 115.
9. Id. at 116.
10. Id.
11. Id.

12. Id. at 127-128.


13. Id. at 79.
14. Id. at 88-92.
15. Id. at 25-26.

16. Mitsubishi Motors Philippines Corporation v. Bureau of Customs , G.R. No. 209830, June 17,
2015, 759 SCRA 306, 310, citing Spouses Genato v. Viola, 625 Phil. 514, 527 (2010).
17. Id.

18. Id., See Philippine Coconut Producers Federation, Inc. v. Republic , 679 Phil. 508 (2012),
citing Allied Domecq Philippines, Inc. v. Villon, 482 Phil. 894, 900 (2004).

19. Batas Pambansa Blg. 129 (1980), as amended by Rep. Act No. 7691 (1994).
20. Id. Sec. 19 (2).
21. Id. Sec. 33 (3).
22. According to the case of Geonzon v. Heirs of Legaspi (586 Phil. 750, 751 [2008]), assessed
value is understood to be the worth or value of property established by taxing authorities
on the basis of which the tax rate is applied. It is synonymous to taxable value and could
be computed by multiplying the fair market value with the assessment level (Hilario v.
Salvador, 497 Phil. 327, 336 [2005]).
23. 564 Phil. 580, 599 (2007), citing Hilario v. Salvador, 497 Phil. 327 (2005).

24. Heirs of Concha, Sr. v. Spouses Lumocso, supra at 596-597.


25. See San Pedro v. Asdala, 611 Phil. 30 (2009).
26. 616 Phil. 177 (2009).
27. Id. at 188.
28. Tumpag v. Tumpag, G.R. No. 199133, September 29, 2014, 737 SCRA 62, 69.

29. 616 Phil. 519 (2009).


30. Id. at 523-524.
31. Hilario v. Salvador, supra note 22, at 336.

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32. Supra note 29.
33. Id. at 527-528.
34. 557 Phil. 650, 661 (2007).
35. Spouses Cruz v. Spouses Cruz, et al., supra note 29, at 528.

36. Quinagoran v. Court of Appeals, supra note 34, at 661.


37. Supra note 28.
38. Id. at 70.
39. Id. at 70-71.
40. 506 Phil. 392, 397 (2005).

41. G.R. No. 204970, February 1, 2016, 782 SCRA 578, 591.
42. Barangay Piapi v. Talip, supra note 40.
43. Id. at 398.
44. Trayvilla v. Sejas, supra note 41.

45. Id. at 592-593.


46. Batas Pambansa Blg. 129 (1980).
47. Rollo, p. 104.
48. Tumpag v. Tumpag, supra note 28.
49. 711 Phil. 274, 285-286 (2013).

50. 701 Phil. 19, 25-26 (2013).


51. 481 Phil. 249 (2004), as cited in Imperial v. Armes, G.R. No. 178842, January 30, 2017.
52. Cañero v. University of the Philippines, id. at 267.

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