Posted by: Roque H. Rios Jr. on 23 July 2018
On August 28, 1998, Barangay Piapi, herein petitioners, filed with the Regional Trial Court (RTC) Branch 18, Digos, Davao del Sur, a complaint for Reconveyance and Damages for a parcel of land consisting of 3.2 hectares situated in Piapi, Davaol del Sur, and covered by Original Certificate of Title (OCT) No. P-(3331)-4244 of the Registry of Deeds issued in the name of Juan Jayag and has a market value of P15,000. They alleged that they have openly possessed such land for thirty (30) years in the concept of owner, and that respondent, Talip, fraudulently obtained from the said Registry of Deeds a Transfer Certificate of Title (TCT) under his name.
Instead of filing an answer, respondent filed a motion to dismiss on the ground that the RTC has no jurisdiction over the case as considering that the assessed value of the land is P6,030. Under Section 33 (3) of Batas Pambansa (BP) Bilang 129, as amended by Republic Act (R.A.) No. 7691, Municipal Circuit Trial Court has exclusive jurisdiction.
Petitioners alleged that jurisdiction is vested in the RTC as the total assessed value of the property is P41,890, as shown by Real Property Field Appraisal and Assessment Sheet dated August 20, 1996 issued by the Provincial Assessor of Davao del Sur, Atty. Marcos D. Risonar, Jr.
On January 12, 1999, RTC Davao dismissed the complaint for lack of jurisdiction hence this certiorari petition alleging that Section 19 (1) of BP Bilang 129, as amended, gives the RTC jurisdiction over the complaint for reconveyance since it is incapable of pecuniary estimation.
Whether or not the Regional Trial Court has jurisdiction over the complaint for reconveyance.
HELD:
The contention is bereft of merit. This case is analogous to Huguete vs Embudo; where petitioners argued that a complaint for annulment of a deed of sale and partition is incapable of pecuniary estimation, and thus falls within the exclusive jurisdiction of the RTC. Supreme Court ruled that the nature of an action is not determined by the caption of the complaint but by the allegations of the complaint and the reliefs prayed for.
When the ultimate objective of the petitioners, is to obtain title to real property, it should be filed in the proper court having jurisdiction over the assessed value of the property subject thereof. However, they failed to alleged therein the assessed value of the subject property. Instead, what they stated was the market value of the land which was at P15,000.00.
The Rule requires that the assessed value of the property, or if there is none, the estimated value thereof, shall be alleged by the claimant. It bears reiterating that what determines
jurisdiction is the allegations in the complaint and the reliefs prayed for. Petitioners' complaint is for reconveyance of a parcel of land. Considering that their action involves the title to or interest in real property, they should have alleged therein its assessed value. However, they only specified the market value or estimated value, which is P15,000.00. Pursuant to the provisions of Section 33 (3), it is the Municipal Circuit Trial Court and not the RTC, which has jurisdiction over the case.
Section 19 (2) of BP Bilang 129. Jurisdiction in civil cases. Regional Trial Courts shall exercise original jurisdiction: (2) In all civil actions which involve the title to, or possession of, real property, or any interest thereon, where the assessed value of the property involved exceeds Twenty thousand pesos (P20,000.00) or for civil actions in Metro Manila, where such value exceeds Fifty thousand pesos (P50,000.00) except actions for forcible entry into and unlawful detainer of lands or buildings, original jurisdiction over which is conferred upon the Metropolitan Trial Courts, Municipal Trial Courts, and Municipal Circuit Trial Courts.
Section 33. Jurisdiction of Metropolitan Trial Courts, Municipal Trial Courts and Municipal Circuit Trial Courts in Civil Cases. Metropolitan Trial Courts, Municipal Trial Courts, and Municipal Circuit Trial Courts shall exercise: (3) Exclusive jurisdiction in all civil actions involve title to, or possession of, real property, or any interest therein where the assessed value of the property or interest therein does not exceed Twenty thousand pesos (P20,000.00) or, in civil actions in Metro Manila, where such assessed value does not exceed Fifty thousand pesos (P50,000.00) exclusive of interest, damages of whatever kind, attorney fees, litigation expenses and costs: Provided, that in cases of land not declared for taxation purposes, the value of such property shall be determined by the assessed value of the adjacent lots.
