Está en la página 1de 1

PADLAN v.

DINGLASAN
Want of Jurisdiction | 20 March 2013 | J. Peralta Sec. 1 of RA 7691. Section 19 of Batas Pambansa Blg. 129, otherwise known as the "Judiciary
Reorganization Act of 1980," is hereby amended to read as follows:
Nature of Case: Petition for Review on Certiorari
Digest maker: Africa Sec. 19. Jurisdiction in civil cases. – Regional Trial Courts shall exercise exclusive
original jurisdiction:
SUMMARY: Through a falsified deed of sale bearing forged signature of Dinglasan, Pasion
was able to sell the lot to Ong, who consequently sold it to Padlan. For failure of the latter to
heed to respondent’s demand to return the lot, respondent filed action for cancellation of (2) In all civil actions which involve the title to, or possession of, real property, or any
transfer certificate of title before RTC. SC granted petitioner’s motion to dismiss on ground interest therein, where the assessed value of the property involved exceeds Twenty
of lack of jurisdiction over the subject matter. Thousand Pesos (P20,000.00) or for civil actions in Metro Manila, where such value
exceeds Fifty Thousand Pesos (P50,000.00), except actions for forcible entry into and
DOCTRINE: Where the ultimate objective of the plaintiffs is to obtain title to real property, it
should be filed in the proper court having jurisdiction over the assessed value of the unlawful detainer of lands or buildings, original jurisdiction over which is conferred
property subject thereof. upon the Metropolitan Trial Courts, Municipal Trial Courts, and Municipal Circuit
Trial Courts; x x x

FACTS:
1. While on board a jeep, Lilia, Dinglasan’s mother had a conversation with Pasion
regarding the sale of lot owned by Dinglasan. Believing that Pasion was a real estate
agent, Lilia gave the latter a copy of the title of the lot in question.
2. Through a falsified deed of sale bearing forged signature of Dinglasan, Pasion was able to
sell the lot to Ong, who consequently sold it to Padlan.
3. Dinglasan demanded that petitioner surrender possession, but the latter refused hence
the filing of cancellation of transfer certificate of title before RTC. Summons was
thereafter served to petitioner thru her mother, Anita.
4. Petitioner now files motion to dismiss on ground of lack of jurisdiction over the person of
the defendant and the subject matter.

ISSUE/S & RATIO:


1. WON the motion to dismiss shall be granted. — YES
- Where the ultimate objective of the plaintiffs is to obtain title to real property, it should be
filed in the proper court having jurisdiction over the assessed value of the property subject
thereof.
- In the case at bar, the amount alleged in the Complaint by respondents for the disputed lot is
only P4,000.00. Therefore, MTC and not the RTC has jurisdiction over the action. All
proceedings in the RTC are null and void.

RULING: RTC decision is null and void. Case dismissed without prejudice.

NOTE: