Padlan v. Dinglasan, G.R. No. G.R. No.

180321 (RTC)

RECIT-READY DIGEST:

PETITIONER/S: EDITHA PADLAN

RESPONDENT/S: ELENITA DINGLASAN AND FELICISIMO DINGLASAN
PONENTE: PERALTA, J.

FACTS:
● Elenita Dinglasan was the registered owner of a parcel of land covered by a TCT. While on
board a jeepney, Elenita’s mother (Lilia), had a conversation with Maura, who Lilia believed
to be a real estate agent. Lilia borrowed the TCT from Elenita and gave it to Maura. Maura
then subdivided the property in the name of Elenita and her husband
● Through a falsified deed of sale bearing the signature of Elenita and her husband, Maura
was able to sell the property to different buyers. Maura sold it to Ong who then sold it to
Padlan.
● After learning of what happened, Elenita demanded Padlan to surrender possession of the
land in question.
● Due to the refusal of Padlan to surrender the property, Eleneita filed a case before the
Regional Trial Court for the cancellation of TCT issued under Padlan.
● Padlan filed a motion to dismiss the case on the ground that the RTC does not have
jurisdiction over the subject matter of the case.
MAIN ISSUE:
● Did the RTC have jurisdiction over the subject matter of the case? - NO
RULING:
● Elenita filed the complaint in 1999 when BP 129 (Judiciary Act of 1980) was amended by
RA 7691 which expanded the jurisdiction of the MTC.
● RA 7691 provides that
○ “the RTC shall exercise exclusive original jurisdiction in civil actions which
involve the title to, or possession of, real property, or any interest therein,
where the assessed value of the property exceeds 20,000 or for civil
actions in Metro MAnila, where such value exceeds 50,000, except
actions for forcible entry into and unlawful detainer of lands or buildings,
original jurisdiction over which is conferred upon the MTCs”
● The nature of an action, as well as which court has jurisdiction over it, are determined
based on the allegations in the complaint.
● In this case, Elenita alleges that without her knowledge and consent, the land was divided
into several lots through fraudulent means of Maura. Maura then sold a parcel of land to
Laura who then sold it to Padlan for 4,000 pesos. Despite demands of Elenita to return
the land, Padlan refuses to return it.
● Hence, Elenita’s action is based on the claim of ownership over the property. The case is
not simply one for cancellation of title since the true ownership must first be determined.
● Here, the value of the land is alleged to be 4,000 as stated in the complaint. Hence, since
the action is for determination of ownership and the land in question is only 4,000, the
MTC has jurisdiction over the case as provided by RA 7691.
● The RTC has no jurisdiction to over the case hence all the proceedings before it are
declared null and void