G.R. No. 174497, 12 October 2009
Posted by: Von Derek on July 25, 2018
FACTS:
On August 10, 1999 plaintiff spouses Generoso and Aurelia Sebe and their daughter, Lydia Sebe, (the Sebes) filed with the RTC of Dipolog City[5] a complaint against defendants Veronico Sevilla and Technology and Livelihood Resources Center for Annulment of Document, Reconveyance and Recovery of Possession of two lots, which had a total assessed value of P9,910.00, plus damages.[6] On November 25, 1999 they amended their complaint[7] to address a deed of confirmation of sale that surfaced in defendant Sevillas Answer[8] to the complaint. The Sebes claimed that they owned the subject lots but, through fraud, defendant Sevilla got them to sign documents conveying the lots to him. In his Answer[9] Sevilla insisted that he bought the lots from the Sebes in a regular manner.
While the case was pending before the RTC, plaintiff Generoso Sebe died so his wife and children substituted him.[10] Parenthetically, with defendant Veronico Sevillas death in 2006, his heirs substituted him as respondents in this case.[11]
On August 8, 2006 the RTC dismissed the case for lack of jurisdiction over the subject matter considering that the ultimate relief that the Sebe sought was the reconveyance of title and possession over two lots that had a total assessed value of less than P20,000.00. Under the law,[12] said the RTC, it has jurisdiction over such actions when the assessed value of the property exceeds P20,000.00,[13] otherwise, jurisdiction shall be with the first level courts.[14] The RTC concluded that the Sebe should have filed their action with the Municipal Trial Court (MTC) of Dipolog City.
THE ISSUE:
Whether or not the Sebe action involving the two lots valued at less than P20,000.00 falls within the jurisdiction of the RTC.
HELD:
No, the power of the RTC under Section 19 of Batas Pambansa 129,[45] as amended,[46] to hear actions involving title to, or possession of, real property or any interest in it now covers only real properties with assessed value in excess of P20,000.00. But the RTC retained the exclusive power to hear actions the subject matter of which is not capable of pecuniary estimation.
SEC. 19. Jurisdiction in Civil Cases. Regional Trial Courts shall exercise exclusive original jurisdiction:
(1) In all civil actions in which the subject of the litigations is incapable of pecuniary estimation.
(2) In all civil actions which involve the title to, or possession of, real property, or any interest therein, 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, on the other hand provides that, if the assessed value of the real property outside Metro Manila involved in the suit is P20,000.00 and below, as in this case, jurisdiction over the action lies in the first level courts. Thus
SEC. 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 original jurisdiction in all civil actions which 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).
The present action is, therefore, not about the declaration of the nullity of the documents or the reconveyance to the Sebe of the certificates of title covering the two lots. These would merely follow after the trial court shall have first resolved the issue of which between the contending parties is the lawful owner of such lots, the one also entitled to their possession. Based on the pleadings, the ultimate issue is whether or not defendant Sevilla defrauded the Sebe of their property by making them sign documents of conveyance rather than just a deed of real mortgage to secure their debt to him. The action is, therefore, about ascertaining which of these parties is the lawful owner of the subject lots, jurisdiction over which is determined by the assessed value of such lots.
Here, the total assessed value of the two lots subject of the suit is P9,910.00. Clearly, this amount does not exceed the jurisdictional threshold value of P20,000.00 fixed by law. The other damages that the Sebes claim are merely incidental to their main action and, therefore, are excluded in the computation of the jurisdictional amount.
