You are on page 1of 1

Case Digest

Hilario vs Salvador

Facts:

Hilario filed a complaint with the RTC against Salvador alleging that they were the co-owners of the parcel of land where Salvador
constructed his house without their knowledge and refused to vacate despite their demands.

Salvodor filed a motion to dismiss the complaint on the ground of lack of jurisdiction. He contended that the complaint did not state
the assessed value of the property, which determines the jurisdiction of the court.

Hilario maintained that the RTC had jurisdiction since their action was an accion reinvindicatoria, an action incapable of pecuniary
estimation; thus, regardless of the assessed value of the subject property, exclusive jurisdiction fell within the said court. Also, in their
opposition to Salvador's motion to dismiss, they mentioned the increase in the assessed value of the land in the amount of P3.5 million.
Moreover, they maintained that their action was also one for damages exceeding P20,000.00, over which the RTC had exclusive
jurisdiction.

Issues:

Whether or not the action filed by Hilario was an accion reinvindicatoria.

Whether or not the RTC had jurisdiction over the complaint filed by Hilario.

Held :The action filed by Hilario did not involve a claim of ownership over the property. They prayed that Salvador vacate the property
and restore possession to them. Hence, it was an accion publiciana, or one for the recovery of possession of the real property. It was
not an aaccion reinvindicatoria or a suit for the recovery of possession over the real property as owner.

The nature of the action and which court has original and exclusive jurisdiction is determined by the material allegations of the
complaint, the type of relief prayed for by the plaintiff and the law in effect when the action is filed, irrespective of whether the
plaintiffs are entitled to some or all of the claims asserted therein.

The complaint did not contain an allegation stating the assessed value of the property. Absent any allegation in the complaint of the
assessed value of the property, it could not thus be determined whether the RTC or the MTC had original and exclusive jurisdiction
over the action.

The law also explicitly excluded from the determination of the jurisdictional amount the demand for interest, damages of whatever
kind, attorneys fees, litigation expenses, and costs.

Since the RTC had no jurisdiction over the action, all the proceedings therein, including the decision of the RTC, were null and void.

You might also like