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ESPERANZA SUPAPO et al vs. SPOUSES ROBERTO AND SUSAN DE JESUS et al.

G.R. No. 198356 April 20,2015

FACTS:
The Spouses Supapo filed a complaint for accion publiciana against Roberto and Susan de Jesus with the MeTC of Caloocan City. The
complaint sought to compel the respondents to vacate a piece of land located in Novaliches, Quezon City, and registered under
petitioners name. The land has an assessed value of Php39,980.00. Petitioners did not reside on the lot but made sure to visit at
least twice a year.

During one of their visits, they saw two houses built on the lot without their knowledge and permission. They learned that
respondents occupied both houses. They demanded the surrender of the lot by bringing the dispute before the appropriate Lupong
Tagapamayapa. The Lupon issued a certificate to file action for failure of the parties to settle amicably.

The Spouses Supapo filed a criminal case against the respondents for violating PD No. 772 (Anti-Squatting Law). The trial court
convicted the respondents. On appeal, the CA dismissed the case because Congress enacted R.A. No. 8368 repealing the Anti-
Squatting Law. Notwithstanding the dismissal, the Spouses Supapo moved for the execution of the respondents civil liability, praying
that the latter vacate the subject lot. The RTC granted the motion and issued the writ of execution. Respondents moved to quash it
but the RTC denied their motion. They filed with the CA a petition for certiorari. The CA granted it and ruled that with the repeal of
the Anti-Squatting Law, the criminal and civil liabilities of respondents were extinguished, but it also said that recourse may be had in
court by filing the proper action for recovery of possession. Thus, the Spouses Supapo filed the complaint for accion publiciana.

After filing their Answer, the respondents moved to set their affirmative defenses for preliminary hearing and argued that there is
another action pending between the same parties, the complaint is barred by statute of limitations, and the petitioners cause of
action is barred by prior judgment.

The MeTC denied the motion to set the affirmative defenses for preliminary hearing. The RTC granted the petition for certiorari of
respondents because the action has prescribed and accion publiciana falls within the exclusive jurisdiction of the RTC. It likewise
denied the motion for reconsideration of petitioners. On appeal, the CA affirmed the RTC decision; hence, this petition.

ISSUES:
1. Whether or not the MeTC properly acquired jurisdiction.
2. Whether or not the cause of action has prescribed.
3. Whether or not the complaint for accion publiciana is barred by res judicata.

HELD:
1. YES. Under BP 129, the jurisdiction of the RTC over actions involving title to or possession of real property is plenary. However, R.A.
No. 7691 granted the MeTC, MTC, and MCTC the exclusive original jurisdiction to hear actions where the assessed value of the
property does not exceed Php20,000 ot Php50,000 if the property is located in Metro Manila. Jurisdiction over actions involving title
to or possession of real property is now determined by its assessed value. It is its fair market value multiplied by the assessment
level.

In the present case, the Spouses Supapo alleged that the assessed value of the subject lot located in Metro Manila is Php39,980.
Thus, the MeTC properly acquired jurisdiction over the complaint for accion publiciana.

2. NO. Lands covered by a title cannot be acquired by prescription or adverse possession. Even it be supposed that the holders of the
Torrens Title were aware of the other persons occupation of the property, regardless of the length of that possession, the lawful
owners have a right to demand the return of their property at any time as long as the possession was unauthorized or merely
tolerated.

3. NO. Res judicata is not present in the case because:


a. First, there is no identity of parties. The criminal complaint was prosecuted in the name of the People of the Philippines. The
accion publiciana was filed in the name of the Spouses Supapo.
b. There is no identity of subject matter. The criminal case involves the prosecution of a crime under the Anti-Squatting Law while the
accion publiciana is an action to recover possession of the subject property.
c. There is no identity of causes of action. The People of the Philippines filed the case to protect governmental interests, while the
spouses filed the accion publiciana to protect their proprietary interests.
PETITION GRANTED.