GR No.

180321
March 20 2013
EDITHA PADLAN, Petitioner,
vs.
ELENITA DINGLASAN and FELICISIMO DINGLASAN, Respondents.
Facts:
Petition for certiorari assailing the decision of the CA dated June 29 2007.
ElenitaDinglasan is the registered owner of Lot No. 625 with an area of 82, 972
sq m. While riding the jeepney, Elenitas mother, Lilia, had a conversation with one
Maura Passion and believed her to be a real estate agent. Lilia borrowed the owners
copy of the TCT from Elenita and gave it to Maura from there, the latter was able to
subdivide the lots and through falsified deeds of sale was able to sell the lots to different
buyers. One of them was Lorna Ong who bought Lot No. 625-K and was later sold to
petitioner EdithaPadlan for P4000, where a new title was issued in her favour. Upon
discovery, respondents demanded that petitioner surrender possession of said lot but
she refused. Later, they filed a case for Cancellation of Transfer Certificate of Title
before the RTC of Balanga, Bataan.
Petitioner claims that RTC did not acquire jurisdiction over her person because
the summons was not validly served upon her but only through her mother and the she
has been living in Japan for a long time after marrying a Japanese national. Documents
were submitted to support this contention but RTC declared her in default upon motion
of the respondents. The trial ensued and she was found to be a buyer in good faith by
the RTC. Upon appeal, CA set aside RTCs findings stating that based on the
surrounding circumstances, the petitioner should have inquired further before buying the
disputed property and not just simply rely on the title. CA concluded that the title issued
in her favour was fraudulent and was therefore null and void. Petitioner then filed for a
motion for reconsideration claiming that the lower court failed to acquire jurisdiction over
the subject matter as well as her person but the same was subsequently denied.
Issues:
I.
II.
III.

WON the Honorable Court had jurisdiction over the person of the Petitioner
WON the Honorable Court had jurisdiction over the subject matter of the case
WON the petitioner was a buyer in good faith for value

Held:
Petiton is meritorious.
SC ruled that before resolving the other issues raised by the petitioner, RTCs
jurisdiction of the subject matter must first be ascertained. The same is conferred by law
and determined by the factual allegations in the complaint as well as the relief sought
therefrom.
An action involving title to real property means that the plaintiffs 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.
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
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 P4,000.00. No
tax declaration was even presented that would show the valuation of the subject
property.
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 P4,000.00, the MTC and not the RTC has jurisdiction over the
action. Therefore all proceedings therefrom are null and void.
SC did not find it necessary to discuss the remaining issues raised by the
petitioner. Decision of the CA is reversed and set aside and complaint is dismissed
without prejudice.