Esperanza Supapo vs Spouses De Jesus

Facts:
- Spouses Supapo owned a piece of land located in Novaliches, Quezon City. They did not reside on the
subject lot and they did not employ an overseer but they made sure to at least visit the land twice (2) a year.
During one of their visits, they saw two (2) houses built on the subject lot, without their knowledge and
permission and was occupied by Spouses de Jesus and Macario.
- Spouses Supapo the demanded from the respondents the immediate surrender of the subject lot by bringing
the dispute to the Lupong Tagapamayapa, in which the Lupon issued a certificate to file an action for failure
of the parties to settle amicably.
- Spouses Supapo then filed before the MeTC a criminal case for the violation of PD 772 (Anti-Squatting
Law), in which the trial court convicted the respondents.
- Respondents appealed before the CA. While the appeal was pending, Congress enacted RA 8368 which
repealed PD 772. This then resulted to the dismissal of the criminal case, which became final.
- Spouses Supapo then moved for the execution of the respondent’s civil liability before the RTC, which
granted the motion and issued a writ of execution. The respondents moved to quash the writ but the RTC
denied the motion and also denied their motion for reconsideration/
- Respondents then filed a writ of certiorari before the CA to challenge the orders of the RTC denying the
quashal of the writ and their motion for reconsideration. The CA then granted the petition and held that with
the repeal of PD 772, the respondent’s criminal and civil liabilities were extinguished.
- Spouses Supapo then filed for action publiciana before the MeTC Caloocan. The MeTC ruled in favor of
Spouses Supapo. Respondents then filed a petition for certiorari with the RTC, in which the RTC granted
the petition because the action publiciana should be filed before the RTC and not the MeTC. Spouses
Supapo then appealed the ruling before the CA, in which the CA ruled in favor of the RTC.
- Petitioners emphasised that the court’s jurisdiction over an action involving title to or possession of land is
determined by its assessed value; that the RTC does not have an exclusive jurisdiction on all complaints
for accion publiciana; and that the assessed value of the subject lot falls within MeTC's jurisdiction.
- RTC ruled that the MeTC had jurisdiction based on the assessed value of the subject lot, the Spouses
Supapos' cause of action had already prescribed, the action having been filed beyond the ten (l0)-year
prescriptive period
- Reckoning period is counted from the time the certificate to file action was issued
- The certificate to file action was issued on November 25, 1992, while the complaint for accion
publiciana was filed only on March 7, 2008, or more than ten (10) years thereafter.

Issue: Whether the MeTC properly acquired jurisdiction

Held:
MeTC has properly acquired jurisdiction
- Under Batas Pambansa Bilang 129, the jurisdiction of the RTC over actions involving title to or possession
of real property is plenary.
- RA 7691, however, divested the RTC of a portion of its jurisdiction and granted the Metropolitan Trial Courts,
Municipal Trial Courts and Municipal Circuit Trial Courts the exclusive and original jurisdiction to hear actions
where the assessed value of the property does not exceed Twenty Thousand Pesos (P20,000.00), or Fifty
Thousand Pesos (P50,000.00), if the property is located in Metro Manila.
- In view of these amendments, jurisdiction over actions involving title to or possession of real property is now
determined by its assessed value.
- NOTE: The assessed value of real property - fair market value x assessment level
- In the present case, the Spouses Supapo alleged that the assessed value of the subject lot, located in Metro
Manila, is P39,980.00. This is proven by the tax declaration issued by the Office of the City Assessor of
Caloocan. The respondents do not deny the genuineness and authenticity of this tax declaration.
- Given that the Spouses Supapo duly complied with the jurisdictional requirements, we hold that the MeTC
of Caloocan properly acquired jurisdiction over the complaint for accion publiciana.