Mere reference to attached document facially resolves question on jurisdiction
The factual allegations in a complaint should be considered in tandem with the statements and inscriptions on the documents attached to it as annexes or integral parts. The RTC should have considered the facts contained in the Declaration of Real Property attached to the complaint in determining whether the RTC had jurisdiction over the petitioner's case. A mere reference to the attached document could facially resolve the question on jurisdiction and would have rendered lengthy litigation on this point unnecessary. (G.R. No. 199133; September 29, 2014).
Record shows that the complaint was filed with the Regional Trial Court on December 13, 1995. There is no allegation whatsoever in the complaint for accion publiciana concerning the assessed value of the property involved. Attached however to the complaint is a copy of the Declaration of Real Property of subject land which was signed by the owner stating that its market value is ₱51,965 and its assessed value is ₱20,790.00.
Generally, the court should only look into the facts alleged in the complaint to determine whether a suit is within its jurisdiction. There may be instances, however, when a rigid application of this rule may result in defeating substantial justice or in prejudice to a party’s substantial right. In Marcopper Mining Corp. v. Garcia, we allowed the RTC to consider, in addition to the complaint, other pleadings submitted by the parties in deciding whether or not the complaint should be dismissed for lack of cause of action. In Guaranteed Homes, Inc. v. Heirs of Valdez, et al., we held that the factual allegations in a complaint should be considered in tandem with the statements and inscriptions on the documents attached to it as annexes or integral parts.
In the present case, we find reason not to strictly apply the above-mentioned general rule, and to consider the facts contained in the Declaration of Real Property attached to the complaint in determining whether the RTC had jurisdiction over the petitioner’s case. A mere reference to the attached document could facially resolve the question on jurisdiction and would have rendered lengthy litigation on this point unnecessary.
Generally, the court should only look into the facts alleged in the complaint to determine whether a suit is within its jurisdiction. There may be instances, however, when a rigid application of this rule may result in defeating substantial justice or in prejudice to a party’s substantial right. In Marcopper Mining Corp. v. Garcia, we allowed the RTC to consider, in addition to the complaint, other pleadings submitted by the parties in deciding whether or not the complaint should be dismissed for lack of cause of action. In Guaranteed Homes, Inc. v. Heirs of Valdez, et al., we held that the factual allegations in a complaint should be considered in tandem with the statements and inscriptions on the documents attached to it as annexes or integral parts.In the present case, we find reason not to strictly apply the above-mentioned general rule, and to consider the facts contained in the Declaration of Real Property attached to the complaint in determining whether the RTC had jurisdiction over the petitioner’s case. A mere reference to the attached document could facially resolve the question on jurisdiction and would have rendered lengthy litigation on this point unnecessary.
