Estrella was the registered owner of a huge parcel of land located in a remote part of their barrio in Benguet. However, when she visited the property after she took a long vacation abroad, she was surprised to see that her childhood friend, John, had established a vacation house on her property. Both Estrella and John were residents of the same barangay.
To recover possession, Estrella filed a complaint for ejectment with the Municipal Trial Court (MTC), alleging that she is the true owner of the land as evidenced by her certificate of title and tax declaration which showed the assessed value of the property as P21,000.00. On the other hand, John refuted Estrella’s claim of ownership and submitted in evidence a Deed of Absolute Sale between him and Estrella. After the filing of John’s answer, the MTC observed that the real issue was one of ownership and not of possession. Hence, the MTC dismissed the complaint for lack of jurisdiction.
On appeal by Estrella to the Regional Trial Court (RTC), a full-blown trial was conducted as if the case was originally filed with it. The RTC reasoned that based on the assessed value of the property, it was the court of proper jurisdiction. Eventually, the RTC rendered a judgment declaring John as the owner of the land and, hence, entitled to the possession thereof. (4%)
(A) Was the MTC correct in dismissing the complaint for lack of jurisdiction? Why or why not?
(B) Was the RTC correct in ruling that based on the assessed value of the property, the case was within its original jurisdiction and, hence, it may conduct a full-blown trial of the appealed case as if it was originally filed with it? Why or why not?
Suggested answer only. Not an official answer and not legal advice.
(A) No, the MTC was incorrect; (B) No, the RTC was also incorrect. Under B.P. Blg. 129 and Rule 70, the MTC has exclusive original jurisdiction over ejectment cases regardless of property value, and raising ownership does not divest it of jurisdiction. Under
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Quick check
Does a defendant's claim of ownership in an answer divest the Municipal Trial Court of jurisdiction over an ejectment suit?
The MTC is not divested of jurisdiction in ejectment cases when ownership is raised, as it may decide ownership provisionally to determine possession.
What is the extent of a Municipal Trial Court's ruling on ownership raised in an ejectment case?
A ruling on ownership in an ejectment suit is provisional and limited solely to determining the right of physical possession.
What is the proper procedural action of the RTC when the MTC improperly dismisses an ejectment case without trial on the merits?
Under Rule 40, Section 8, the RTC must reverse an improper MTC dismissal rendered without trial and remand the case to the MTC.
Which court has exclusive original jurisdiction over actions for forcible entry and unlawful detainer regardless of property value?
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Under Rule 40, Section 8, when may the RTC try an appealed case as if it were originally filed with it?
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Learn more about these topics
1. Ejectment Jurisdiction
Under Batas Pambansa Blg. 129 and Rule 70 of the Rules of Court, Municipal Trial Courts possess exclusive original jurisdiction over ejectment suits involving unlawful detainer or forcible entry regardless of the value of the property involved. The nature of an action is determined by the allegations in the complaint, not by the defenses raised in the answer. Where a complaint properly alleges facts constituting an ejectment action, the trial court retains full authority to hear and adjudicate the dispute regarding physical possession.
2. Provisional Ownership
When a defendant in an ejectment suit raises the defense of ownership, the Municipal Trial Court is not divested of its jurisdiction to try the case. Under Section 16, Rule 70 of the Rules of Court, the court may provisionally resolve the issue of ownership solely for the purpose of determining who between the parties has the better right to physical possession. This provisional determination does not bind the title of the property nor bar a separate action between the same parties regarding ownership.
3. Rule 40 Remand
Under Section 8, Rule 40 of the Rules of Court, when a case appealed to the Regional Trial Court was dismissed by the Municipal Trial Court without trial on the merits upon a question of law, the Regional Trial Court cannot immediately conduct a full-blown trial under its original jurisdiction unless the trial court properly lacked jurisdiction. If the Municipal Trial Court improperly dismissed the case despite having jurisdiction, the Regional Trial Court on appeal must reverse the dismissal and remand the case for trial.