Beruflich Dokumente
Kultur Dokumente
the case in view of the fact that the assessed value of the subject
ROSARIO M. SABITSANA, Petitioners, vs. land was only P1,230.00. Respondent counters that a suit for
JUANITO F. MUERTEGUI, represented by his quieting of title is one whose subject matter is incapable of
Attorney-in-Fact DOMINGO A. pecuniary estimation, and thus falls within the jurisdiction of
MUERTEGUI, JR., Respondent. [G.R. No. 181359, August 5, the RTC.
2013, DEL CASTILLO, J.]
ISSUE: Does the RTC have jurisdiction over the suit for
On the question of jurisdiction, it is clear under the Rules that an quieting of title?
action for quieting of title may be instituted in the RTCs,
regardless of the assessed value of the real property in dispute. RULING: YES. The Regional Trial Court has jurisdiction over
Under Rule 63 of the Rules of Court, an action to quiet title to real the suit for quieting of title.
property or remove clouds therefrom may be brought in the
appropriate RTC. On the question of jurisdiction, it is clear under the
Rules that an action for quieting of title may be instituted in
In 1981, Alberto Garcia (Garcia) executed an the RTCs, regardless of the assessed value of the real property
unnotarized Deed of Sale in favor of respondent Juanito over a in dispute. Under Rule 63 of the Rules of Court, an action to
7,500-square meter parcel of unregistered land located in quiet title to real property or remove clouds therefrom may be
Dalutan Island, Talahid, Almeira, Biliran, Leyte del Norte brought in the appropriate RTC.
covered by a tax declaration in Garcia’s name.
It must be remembered that the suit for quieting of title
Juanito’s father Domingo Muertegui, Sr. (Domingo Sr.) was prompted by petitioners’ August 24, 1998 letter-opposition
and brother Domingo Jr. took actual possession of the lot and to respondent’s application for registration. Thus, in order to
planted thereon coconut and ipil-ipil trees. They also paid the prevent a cloud from being cast upon his application for a title,
real property taxes on the lot for the years 1980 up to 1998. respondent filed Civil Case No. B-1097 to obtain a declaration of
his rights. In this sense, the action is one for declaratory relief,
In 1991, Garcia sold the lot to the Muertegui family which properly falls within the jurisdiction of the RTC pursuant
lawyer, Atty. Sabitsana, through a notarized deed of absolute to Rule 63 of the Rules.
sale. The sale was registered with the Register of Deeds on 1992.
Although Domingo Jr. and Sr. paid the real estate taxes, Atty.
Sabitsana also paid real property taxes in 1992, 1993, and 1999.
In 1996, Atty. Sabitsana introduced concrete improvements on
the property, which shortly thereafter were destroyed by a
typhoon.