[54] TRAYVILLA V.

SEJAS
G.R. No. 204970 | February 1, 2016 | Del Castillo, J. | RTC or MTC
NATURE OF THE CASE: Petition for Review on Certiorari assailing CA Decision
which granted Respondents’ Petition for Certiorari and nullified RTC Pagadian Br.
18’s Orders, and CA Resolution denying Petitioners’ MR
canceled and the property be reconveyed to them; and that they be
awarded P50,000.00 in moral damages, in addition to the P30,000.00
attorney's fees and P1,500.00 per court appearance of counsel
originally prayed for in the Complaint
 However, the additional docket fees for the moral damages prayed for in the
Amended Complaint were not paid, nor were docket fees charged and paid for
additional causes of action

SUMMARY: The petitioners filed a complaint for specific performance and damages
against the respondents but failed to indicate the FMV of the property as stated in the
Tax Declaration or current zonal valuation of the BIR, whichever is higher. Due to the
absence of such information, it could not be determined whether or not the RTC or
MTC had original and exclusive jurisdiction over the action as the value was
necessary for the computation of the docket fees. In this case, the Court held that
despite the failure of the petitioners to indicate the value, Rule 141, RoC, as amended
by Am 04-2-04-SC & SC Amended Admin. Circ. 35-2004, provides that the value of
the property as alleged by the claimant should be used as a basis. Since the value
was just Php6,000, RTC did not have jurisdiction over the matter.
DOCTRINE:
Well-entrenched rule is to the effect that a court acquires jurisdiction over a case only
upon the payment of the prescribed filing and docket fees. The general rule is that the
amount of docket fees is determined by the FMV of the property as stated in the Tax
Declaration or current zonal valuation of the BIR, whichever is higher. In the absence
of both values, the value as alleged in the complaint will be used as a basis.
FACTS:
 In their complaint for specific performance and damages, petitioners Claudio and
Carmencita Trayvilla claimed among others
o That Sejas was the registered owner of a parcel of land in Tukuran,
Zamboanga del Sur
o That by virtue of a private handwritten document, Sejas sold said parcel
of land to them in 1982;
o That thereafter, they took possession of the land and constructed a
house thereon;
o That they resided in said house and continued to reside therein;
o That Sejas later reasserted his ownership over said land and was thus
guilty of fraud and deceit in so doing; and
o That they caused the annotation of an adverse claim.
o They prayed that Sejas be ordered to execute a final deed of sale over
the property and transfer the same to them, and that they be awarded
the sum of P30,000.00 as attorney's fees plus P1,500.00 per court
appearance of counsel
 Amended Complaint (for specific performance, reconveyance, and damages):
petitioners impleaded respondent Juvy Paglinawan as additional defendant,
claiming
o That Sejas subsequently sold the property to her; and
o That after, she caused the cancellation of TCT T8,337 and the issuance
of a new title TCT T46,627 in her name
o Prayed that Sejas be ordered to execute a final deed of sale in their
favor and transfer the property to them; that Paglinawan's TCT be
PROCEDURAL HISTORY:
1. 2005: Petitioners instituted the civil case against the respondent before the
RTC.
2. Respondents moved for dismissal of the case, claiming lack of jurisdiction
over the subject matter and prescription. This was denied by the RTC.
3. Respondents filed an MR
- argued the case was not for specific performance but really a real action
involving title to and possession of real property, in which case the value
of the property should be alleged to properly compute and pay the filing
fee; since the value was not alleged in the Amended Complaint, the
proper fee was not paid, so the case should be dismissed;
- cause of action is barred by prescription since the 10-year period to sue
upon the handwritten contract, counted from the purchase of land in
1982, had already lapsed when they filed the case in 2005
4. RTC denied, holding petitioners’ case not a real action but one for specific
performance and thus one which is incapable of pecuniary estimation
5. Respondents filed with CA a Petition for Certiorari which was granted by the
CA.
- Sec. 1, Rule 141 of the Revised Rules of Court: well-entrenched rule is
to the effect that a court acquires jurisdiction over a case only upon the
payment of the prescribed filing and docket fees.
- While it may appear that the suit filed is one for specific performance,
the Complaint shows that the petitioners were also asking the RTC to
secure their vaunted ownership and title to the land which they claimed
was purchased by Sejas. A real action is thus involved.
- The determination of docket fees is based on the FMV of the property.
Since the petitioners did not allege the FMV of the property as stated in
the Tax Declaration or current zonal valuation of the BIR (whichever is
higher), it cannot be determined whether the RTC or MTC has original
and exclusive jurisdiction over the matter.
- There is therefore no showing on the face of the complaint that the RTC
has exclusive jurisdiction over the action of the private respondents.
Hence, the RTC erred in taking cognizance of the case despite
petitioners’ nonpayment of the correct docket fees which must be
computed in accordance with Section 7(1), Rule 141 of the Rules of
Court, as amended.
6. MR filed by the petitioners was denied by the CA. Hence, this petition.
ISSUES AND RATIO:
1. W/N CA erred in dismissing the complaint by reason of petitioners’ alleged
non-payment of the correct docket fees due to their failure to include the
 FMV or the stated value of the subject property in the Amended Complaint. – Php6,000 (based on the handwritten document sued upon, as well as the
NO pleadings)
 Rule 141, RoC, as amended by Am 04-2-04-SC & SC Amended Admin. Circ. 35-
2004, provides:
 While petitioners’ Amended Complaint was denominated as one mainly for o a) For filing an action or a permissive OR COMPULSORY counterclaim,
specific performance, they also prayed for reconveyance of the property and the CROSSCLAIM, or money claim against an estate not based on
cancellation of Paglinawan's TCT judgment, or for filing a thirdparty, fourth party, etc. complaint, or a
o Their aim was to secure their claimed ownership and title to the subject complaintinintervention, if the total sum claimed, INCLUSIVE OF
property, which qualifies their case as a real action INTERESTS, PENALTIES, SURCHARGES, DAMAGES OF
o Sec. 1, Rule 5, 1997 Rules of Civil Procedure: a real action is one that WHATEVER KIND, AND ATTORNEY'S FEES, LITIGATION
affects title to or possession of real property, or an interest therein EXPENSES AND COSTS and/or in cases involving property, the FAIR
 Since it is a real action, petitioners should’ve observed the requirement under AM MARKET value of the REAL property in litigation STATED IN THE
04-2-04-SC relative to declaring the FMV of the property as stated in the current CURRENT TAX DECLARATION OR CURRENT ZONAL VALUATION
tax declaration or zonal valuation of the BIR OF THE BUREAU OF INTERNAL REVENUE, WHICHEVER IS
o Since no such allegation was made in the Amended Complaint, then the HIGHER, OR IF THERE IS NONE, THE STATED VALUE OF THE
value of the subject property as stated in the handwritten document PROPERTY IN LITIGATION OR THE VALUE OF THE PERSONAL
sued upon and restated in the Amended Complaint should be the basis PROPERTY IN LITIGATION AS ALLEGED BY THE CLAIMANT
for determining jurisdiction and the amount of docket fees to be paid  shall be the basis for computing docket fees.
 Since the value is just Php6,000, the RTC did not have jurisdiction over the case
2. W/N the filing of the Amended Complaint sufficiently divested the RTC of its and should have dismissed it. RTC committed grave abuse of discretion.
jurisdiction over the case that had initially validly attached by virtue of the
original complaint. - YES
DISPOSITIVE: WHEREFORE, petition DENIED. CA Decision & Resolution
 In the absence of the required declaration, it cannot be determined whether the AFFIRMED
RTC or first level court has original and exclusive jurisdiction over the action,
since the jurisdiction of these courts is determined on the basis of the value of
the property
o Sec. 19, BP 129: RTCs shall exercise exclusive original jurisdiction:
1) In all civil actions in which the subject of the litigation is
incapable of pecuniary estimation;
2) In all civil actions which involve the title to, or possession of,
real property, or any interest therein, where the assessed value
of the property involved exceeds Php20,000 or, for civil actions
in Metro Manila, where such value exceeds Php50,000, except
actions for forcible entry into and unlawful detainer of lands or
buildings, original jurisdiction over which is conferred upon the
MeTCs, MTCs, and MCTCs
o Sec. 33, BP 129: MeTCs, MTCs, and MCTCs shall exercise:
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3) Exclusive original jurisdiction in all civil actions which involve
title to, or possession of, real property, or any interest therein
where the assessed value of the property or interest therein
does not exceed Php20,000 or, in civil actions in Metro Manila,
where such assessed value does not exceed Php50,000
exclusive of interest, damages of whatever kind, attorney's
fees, litigation expenses and costs: Provided, That in cases of
land not declared for taxation purposes, the value of such
property shall be determined by the assessed value of the
adjacent lots
 But 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