Understanding Jurisdiction in Property Disputes: It’s About the Assessed Value of the Area in Question

G.R. No. 253531, July 10, 2023, Elizabeth Vidal-Plucena vs. Hon. Flaviano Balgos, Jr., Harvey Glenn Valencia, and Mrs. Franson Valencia

Imagine you own a large piece of land, and a neighbor encroaches on a small portion of it. You decide to sue to recover that portion. But which court should you go to – the Municipal Trial Court or the Regional Trial Court? The answer hinges on a critical factor: the assessed value of the specific area being contested, not the entire property.

This was the core issue in the Supreme Court case of Elizabeth Vidal-Plucena vs. Hon. Flaviano Balgos, Jr., et al. The case clarifies how to determine the correct court jurisdiction when dealing with disputes over portions of land, emphasizing that the assessed value of the specific area in question is the deciding factor.

The Legal Framework: Jurisdiction Over Real Property Disputes

In the Philippines, jurisdiction over cases involving real property is determined by Batas Pambansa Blg. 129, as amended by Republic Act No. 7691. These laws delineate the jurisdiction between the Regional Trial Courts (RTCs) and the Metropolitan Trial Courts (MeTCs), Municipal Trial Courts (MTCs), and Municipal Circuit Trial Courts (MCTCs).

The key provision is that both levels of courts have jurisdiction over actions involving title to, or possession of, real property, or any interest therein. However, the *assessed value* of the property dictates which court has exclusive original jurisdiction.

Here’s the breakdown:

• RTCs have jurisdiction if the assessed value of the property *exceeds* Twenty Thousand Pesos (₱20,000.00), or Fifty Thousand Pesos (₱50,000.00) in Metro Manila.
• MeTCs, MTCs, and MCTCs have jurisdiction if the assessed value of the property *does not exceed* Twenty Thousand Pesos (₱20,000.00), or Fifty Thousand Pesos (₱50,000.00) in Metro Manila.

Let’s look at the specific wording of the law:

Section 19(2) of Batas Pambansa Blg. 129 states that RTCs have exclusive original jurisdiction “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 [T]housand [P]esos ([P]20,000.00) or for civil actions in Metro Manila, where such value exceeds Fifty thousand pesos ([P]50,000.00)…”

Section 33(3) states that MeTCs, MTCs and MCTCs have “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 Twenty [T]housand [P]esos ([P]20,000.00) or, in civil actions in Metro Manila, where such assessed value does not exceed Fifty [T]housand [P]esos ([P]50,000.00)…”

Therefore, the assessed value is the critical determinant. But what happens when the dispute involves only a portion of a larger property?

Hypothetical Example: Suppose you own a 5,000 sq. m. lot with an assessed value of P60,000. Your neighbor builds a fence that encroaches 50 sq. m. onto your property. Even though the entire lot’s assessed value is above the MTC jurisdiction, the court will need to determine the assessed value of just the 50 sq. m. portion that is in dispute.

The Case of Vidal-Plucena vs. Balgos: A Matter of Square Meters

Elizabeth Vidal-Plucena filed a complaint for Recovery of Possession and Damages against Flaviano Balgos, Jr., Harvey Glenn Valencia, and Mrs. Franson Valencia, alleging that they had illegally occupied a portion of her land.

Here’s a timeline of the key events:

• Plucena claimed ownership of a parcel of land covered by TCT No. T-19220, which she inherited.
• In 2013, she discovered that the respondents had entered and fenced off a portion of the land, erecting small concrete houses and pigpens.
• A survey revealed that the occupied portion was approximately 60 square meters.
• Plucena filed a complaint with the RTC, using the assessed value of the entire property (P34,160.00) as the basis for jurisdiction.
• The respondents argued that the RTC lacked jurisdiction because the assessed value should be based only on the 60 square meters in question, which was much lower.

The RTC agreed with the respondents and dismissed the complaint, leading Plucena to elevate the case to the Supreme Court. Plucena argued that the law does not distinguish whether the title to or interest in the property be in whole or in part.

The Supreme Court disagreed with Plucena, stating:

“It is quite clear therefore that what determines jurisdiction is assessed value of the ‘property involved’ or ‘interest therein.’ Surely, there could no other (sic) ‘property involved’ or ‘interest therein’ in this case than the 60 square meters portion allegedly encroached and occupied by and being recovered in this suit from the defendants. The assessed value of the entire ONE HECTARE property in the name of the plaintiff could not be the basis in determining the court’s jurisdiction because such entire property is not involved in this case.”

The Court further emphasized that Plucena could not choose which assessed value to use to forum shop. The assessed value of the 60-square meter portion should be the basis for determining jurisdiction.

“The 60-square meter portion can always be the subject of segregation and thus, its approximate value can be easily determined through the extant records which, in this case, is a tax declaration. However, Plucena failed to do so.”

Practical Implications: What This Means for Property Owners

This case highlights the importance of accurately determining the assessed value of the specific portion of land involved in a dispute. Property owners need to understand that the assessed value of their entire property is not necessarily the determining factor for court jurisdiction in encroachment or boundary disputes.

Key Lessons:

• Assess the Specific Area: In property disputes involving only a portion of land, determine the assessed value of that specific area.
• Segregation is Key: The portion in question can be segregated, and its approximate value determined through tax declarations or other relevant records.
• Avoid Forum Shopping: Plaintiffs cannot choose which assessed value to use to manipulate court jurisdiction.
• Hierarchy of Courts: Direct recourse to the Supreme Court is improper. Cases should first be brought to the lower courts.

Practical Advice: If you are involved in a property dispute, consult with a real estate lawyer to accurately assess the value of the property in question and determine the appropriate court to file your case. Failure to do so can result in dismissal of your case due to lack of jurisdiction.

Frequently Asked Questions (FAQs)

Q: What is assessed value?

A: Assessed value is the value assigned to a property by the local government for taxation purposes. It is usually lower than the market value of the property.

Q: How do I find the assessed value of my property?

A: You can find the assessed value of your property on your property tax bill or by contacting your local assessor’s office.

Q: What happens if the assessed value of the property is not declared for taxation purposes?

A: 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.

Q: Can I appeal the assessed value of my property?

A: Yes, you can usually appeal the assessed value of your property if you believe it is too high. Contact your local assessor’s office for information on the appeals process.

Q: What is forum shopping, and why is it not allowed?

A: Forum shopping is the practice of choosing a court that is most likely to rule in your favor. It is not allowed because it undermines the integrity of the judicial system.

ASG Law specializes in real estate law and property disputes. Contact us or email hello@asglawpartners.com to schedule a consultation.