The Supreme Court ruled that Regional Trial Courts (RTCs) have appellate jurisdiction over all cases decided by Metropolitan Trial Courts (MTCs), Municipal Trial Courts, and Municipal Circuit Trial Courts, regardless of the assessed value of the property involved. This means that if a case is appealed from a lower court (MTC) to the RTC, the RTC has the authority to review and decide the case, even if the assessed value of the property is not stated in the original complaint. The decision clarifies the scope of appellate jurisdiction, ensuring that RTCs can effectively oversee and correct errors made by lower courts, maintaining a consistent application of the law.

Land Dispute Tango: When Appellate Courts Call the Tune

This case arose from a complaint for unlawful detainer filed by Danilo Arrienda against Rosario Kalaw, alleging that Kalaw was occupying a portion of his land in Calauan, Laguna, under the condition that she would vacate the premises upon notice. Kalaw countered that the MTC lacked jurisdiction because the issue was ownership, not just possession, and that she was a tenant who had later acquired ownership through a donation. The MTC dismissed the complaint for lack of jurisdiction, a decision that Arrienda appealed to the RTC, which then ruled in his favor. Kalaw, aggrieved, elevated the case to the Court of Appeals (CA), which reversed the RTC decision, holding that the RTC lacked jurisdiction because Arrienda failed to state the assessed value of the property in his complaint.

The Supreme Court disagreed with the Court of Appeals, emphasizing the distinction between the original and appellate jurisdiction of the RTC. The Court reiterated that RTCs have appellate jurisdiction over all cases decided by first-level courts within their territorial jurisdiction, as explicitly stated in Section 22 of Batas Pambansa Bilang 129 (B.P. Blg. 129), as amended by Republic Act No. 7691 (RA 7691). This appellate jurisdiction is not limited by the assessed value of the property, unlike the original jurisdiction of the RTC, which requires the assessed value to exceed a certain threshold for cases involving title to or possession of real property.

The Court emphasized that the requirement to allege the assessed value of the property applies only when the RTC is exercising its original jurisdiction. In this case, the RTC was exercising its appellate jurisdiction, and therefore, the failure to state the assessed value in the original complaint was irrelevant. The Supreme Court quoted Section 22 of B.P. Blg. 129, as amended:

SECTION 22. Appellate jurisdiction. — Regional Trial Courts shall exercise appellate jurisdiction over all cases decided by Metropolitan Trial Courts, Municipal Trial Courts, and Municipal Circuit Trial Courts in their respective territorial jurisdictions. Such cases shall be decided on the basis of the entire record of the proceedings had in the court of origin such memoranda and/or briefs as may be submitted by the parties or required by the Regional Trial Courts.

The Supreme Court underscored that the RTC’s competence to make findings on Arrienda’s cause of action in the exercise of its appellate jurisdiction is similar to that in its original jurisdiction. The appellate court’s role is to review the decision of the lower court and make a determination based on the evidence and arguments presented.

Building on this principle, the Court clarified the purpose behind requiring the assessed value of the property to be stated in complaints involving real property. This requirement is crucial for determining which court (MeTC/MTC/MCTC or RTC) has original jurisdiction over the action. However, this requirement does not extend to cases where the RTC is exercising its appellate jurisdiction. The Supreme Court referred to its previous ruling in Serrano v. Gutierrez, emphasizing that the assessed value is immaterial when the RTC is acting as an appellate court.

Moreover, the Supreme Court emphasized that all cases decided by the MTC are generally appealable to the RTC, regardless of the amount involved. In Wilfred De Vera, et al. v. Spouses Engenio, Sr. and Esperanza H. Santiago, the Court reiterated that the assessed value of the disputed property is not a factor in determining the RTC’s appellate jurisdiction. This ensures that decisions made by lower courts can be reviewed and corrected, safeguarding the rights of the parties involved.

In summary, the Supreme Court’s decision in this case reinforces the RTC’s role as an appellate court with broad authority to review decisions of lower courts, irrespective of the assessed value of the property involved. This ensures that justice is served by allowing a higher court to correct errors and maintain consistency in the application of the law.

FAQs

What was the key issue in this case?	The central issue was whether the RTC had jurisdiction to hear the appeal from the MTC, given that the assessed value of the property was not stated in the original complaint.
What is the difference between original and appellate jurisdiction?	Original jurisdiction is the power of a court to hear a case for the first time, while appellate jurisdiction is the power of a court to review and revise the decision of a lower court.
Why did the Court of Appeals reverse the RTC decision?	The Court of Appeals reversed the RTC decision because it believed that the RTC lacked jurisdiction since Arrienda did not disclose the assessed value of the property in his complaint.
What did the Supreme Court rule regarding the RTC’s jurisdiction?	The Supreme Court ruled that the RTC had appellate jurisdiction over the case, regardless of whether the assessed value of the property was stated in the original complaint.
Does the assessed value of the property matter in all cases involving real property?	No, the assessed value of the property is only relevant when determining which court has original jurisdiction over the case; it does not limit the RTC’s appellate jurisdiction.
What is the significance of Section 22 of B.P. Blg. 129?	Section 22 of B.P. Blg. 129 grants the RTC appellate jurisdiction over all cases decided by lower courts within their territorial jurisdiction, without regard to the amount or value involved.
What happens to the RTC decision after the Supreme Court’s ruling?	The Supreme Court reinstated the RTC decision, meaning the original order for Rosario Kalaw to vacate the property and pay rent and attorney’s fees was upheld.
What practical impact does this ruling have on property disputes?	This ruling clarifies that RTCs have broad appellate powers in property disputes, ensuring decisions of lower courts can be reviewed and corrected, promoting fairness and consistency in the application of the law.

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: Heirs of Danilo Arrienda vs. Rosario Kalaw, G.R. No. 204314, April 6, 2016