The Supreme Court clarified the proper procedure for appealing decisions in property disputes, emphasizing that the mode of appeal depends on whether the Regional Trial Court (RTC) acted in its original or appellate jurisdiction. In Darma Maslag v. Elizabeth Monzon, the Court held that when an RTC reviews a Municipal Trial Court (MTC) decision, it exercises appellate jurisdiction, requiring a Petition for Review under Rule 42, not an ordinary appeal under Rule 41. This distinction is crucial because choosing the wrong mode of appeal can lead to dismissal, as it did in this case, underscoring the importance of correctly identifying the source of the RTC’s authority in hearing the case.

From MTC to CA: Charting the Course of Jurisdiction in Reconveyance Cases

The case revolves around a complaint filed by Darma Maslag for the reconveyance of property against Elizabeth Monzon, William Geston, and the Registry of Deeds of Benguet. Maslag claimed Monzon fraudulently obtained an Original Certificate of Title (OCT) over her property. The Municipal Trial Court (MTC) initially ruled in favor of Maslag, finding Monzon guilty of fraud and ordering the reconveyance. Monzon appealed to the Regional Trial Court (RTC), which then declared that the MTC lacked jurisdiction, and decided to take cognizance of the case based on Section 8, Rule 40 of the Rules of Court.

Subsequently, the RTC reversed the MTC’s decision. Maslag then filed a Notice of Appeal, seeking to reverse the RTC’s decision. The Court of Appeals (CA), however, dismissed Maslag’s appeal, holding that she availed of the wrong mode of appeal. The CA stated that because the RTC rendered its decision in its appellate jurisdiction, the proper recourse should have been a Petition for Review under Rule 42, and not an ordinary appeal. This brings to the forefront the critical issue of jurisdiction, and the correct procedure for appealing decisions made in its exercise.

The Supreme Court’s analysis hinged on determining whether the RTC acted in its original or appellate jurisdiction. To clarify, the Court examined the nature of Maslag’s original complaint. The action for reconveyance, the Court emphasized, is an action involving title to real property. Jurisdiction in such cases is determined by the assessed value of the property, as provided under Batas Pambansa Blg. 129 (BP 129), as amended by Republic Act (RA) No. 7691. These laws delineate the jurisdictions of the Regional Trial Courts (RTCs) and the Municipal Trial Courts (MTCs).

Sec. 19. Jurisdiction in civil cases. – Regional Trial Courts 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 Twenty thousand pesos (P20,000.00) or for civil actions in Metro Manila, where x x x the [assessed] value [of the property] exceeds Fifty thousand pesos ([P]50,000.00) except actions for forcible entry into and unlawful detainer of lands or buildings, original jurisdiction over which is conferred upon Metropolitan Trial Courts, Municipal Trial Courts, and Municipal Circuit Trial Courts;

The Court noted that the assessed value of the property in question was only P12,400, an amount falling within the jurisdiction of the MTC. This rendered the RTC’s declaration that the MTC lacked jurisdiction erroneous. Despite this, the Supreme Court acknowledged that the RTC actually treated the case as an appeal from the MTC decision, further solidifying that the RTC exercised appellate, not original jurisdiction. Therefore, the Supreme Court concurred with the Court of Appeals’ dismissal of Maslag’s appeal.

The Supreme Court addressed the procedural misstep directly, noting that the correct mode of appeal is determined by the jurisdiction the RTC exercises. This means that if the RTC is hearing a case originally decided by the MTC, it is acting in its appellate capacity. Therefore, a Petition for Review under Rule 42 is the appropriate remedy. The Court was firm in stating that parties could not, by agreement or conduct, confer jurisdiction where the law does not provide it. This is a fundamental principle, ensuring adherence to jurisdictional mandates.

SECTION 2.  Dismissal of improper appeal to the Court of Appeals. – An appeal under Rule 41 taken from the Regional Trial Court to the Court of Appeals raising only questions of law shall be dismissed, issues purely of law not being reviewable by said court.  Similarly, an appeal by notice of appeal instead of by petition for review from the appellate judgment of a Regional Trial Court shall be dismissed.

An appeal erroneously taken to the Court of Appeals shall not be transferred to the appropriate court but shall be dismissed outright. (Emphasis supplied)

The Supreme Court emphasized that jurisdictional errors cannot be overlooked, even at advanced stages of the proceedings. It has the power to review these issues *motu proprio*, underscoring the non-waivable nature of jurisdiction. This power ensures that courts act within their legal bounds, safeguarding the integrity of the judicial process. Even though the RTC initially erred in claiming original jurisdiction, the Supreme Court focused on the actual nature of the proceedings. The RTC’s resolution was essentially an appellate review, making Rule 42 the correct mode of appeal.

FAQs

What was the key issue in this case?	The key issue was whether the petitioner availed of the correct mode of appeal from a decision of the Regional Trial Court (RTC), which had reversed the Municipal Trial Court’s (MTC) judgment in a case involving the reconveyance of real property.
What is the difference between Rule 41 and Rule 42 appeals?	Rule 41 governs ordinary appeals from the RTC when it exercises original jurisdiction, while Rule 42 applies when the RTC exercises appellate jurisdiction over MTC decisions. The proper rule depends on whether the RTC is hearing the case for the first time or reviewing a lower court’s decision.
How is jurisdiction determined in cases involving title to real property?	Jurisdiction is determined based on the assessed value of the property. If the assessed value exceeds P20,000 (or P50,000 in Metro Manila), the RTC has jurisdiction; otherwise, the MTC has jurisdiction.
What happens if a party chooses the wrong mode of appeal?	If a party chooses the wrong mode of appeal, such as filing an ordinary appeal instead of a petition for review, the appeal will be dismissed. It is crucial to select the correct procedure to ensure the appeal is properly heard.
Can parties agree to confer jurisdiction on a court that does not have it?	No, parties cannot confer jurisdiction on a court through agreement or conduct. Jurisdiction is conferred by law, and its absence cannot be waived or stipulated.
What does “motu proprio” mean?	“Motu proprio” means that the court can act on its own initiative, without a motion from either party. In this context, the Supreme Court can review jurisdictional issues even if they are not raised by the parties.
What was the assessed value of the property in this case?	The assessed value of the property was P12,400, which fell within the jurisdiction of the Municipal Trial Court (MTC).
Why did the Court of Appeals dismiss the appeal?	The Court of Appeals dismissed the appeal because the petitioner filed an ordinary appeal (Rule 41) instead of a petition for review (Rule 42), which was the correct mode of appeal given that the RTC was exercising appellate jurisdiction.

In conclusion, Darma Maslag v. Elizabeth Monzon underscores the critical importance of understanding jurisdictional rules and appellate procedure. The decision highlights that choosing the correct mode of appeal is essential to ensuring that legal rights are properly adjudicated, emphasizing that failure to adhere to these rules can lead to the dismissal of an appeal.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: Darma Maslag v. Elizabeth Monzon, G.R. No. 174908, June 17, 2013