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	GR No. 182349 2013-07-24	REMAN RECIO v. ALTAMIRANO REYES, J.
In Alcantara v. Nido,[25] the Court emphasized the requirement of an SPA before an agent may sell an immovable property. In the said case, Revelen was the owner of the subject land. Her mother, respondent Brigida Nido accepted the petitioners' offer to buy Revelen's land at Two Hundred Pesos (P200.00) per sq m. However, Nido was only authorized verbally by Revelen. Thus, the Court declared the sale of the said land null and void under Articles 1874 and 1878 of the Civil Code.[26]
	GR No. 173351 2010-07-29	BF CITILAND CORPORATION v. MARILYN B. OTAKE CARPIO, J.
Under BP 129, as amended, jurisdiction even in accion publiciana cases is determined by the assessed value of the property.[39] The Court recently explained in Spouses Alcantara v. Nido[40] that assessed value is the worth or value of the property as fixed by the taxing authorities for the purpose of determining the applicable tax rate. The assessed value does not necessarily represent the true or market value of the property.[41]