COPIOSO v COPIOSO
G.R. No. 149243. October 28, 2002
BELLOSILLO, J.:
FACTS:
Respondents filed a complaint for reconveyance of two (2) parcels of coconut land against the
petitioner. The complaint was for "Reconveyance and/or Recovery of Common Properties Illegally
Disposed, with Annulment of Sales and other Instruments of False Conveyance, with Damages, and
Restraining Order." Respondents alleged that they together with their deceased brother Antonio
Copioso were co-owners of the subject property having inherited the same from their parents, and that
through fraud and machination Antonio had the property transferred to his name and that of spouses
Bernabe and Imelda Doria who subsequently sold the same to third parties. They thus prayed for the
reconveyance of the property by virtue of their being co-owners thereof.
When respondents claimed in a manifestation with motion for bill of particulars that the assessed value
of the subject property was P3,770.00, petitioners moved to dismiss the complaint on the ground that
it was the MTC and not the RTC that had jurisdiction over the case considering that the assessed value
of the property was lower than P20,000.00. RTC denied the motions to dismiss holding that since the
subject matter of the action was beyond pecuniary estimation it was properly within its jurisdiction.
MR was denied. CA upheld RTC. Hence, this petition.
ISSUE:
WON the action is incapable of pecuniary estimation.
HELD:
YES. This is a case of joinder of causes of action which comprehends more than the issue of title to,
possession of, or any interest in the real property under contention but includes an action to annul
contracts, reconveyance or specific performance, and a claim for damages, which are incapable of
pecuniary estimation and thus properly within the jurisdiction of the RTC.
If the only issue involved herein is naked possession or bare ownership, then petitioner Lolita Copioso
would not be amiss in her assertion that the instant complaint for reconveyance, considering the
assessed value of the disputed property, falls within the exclusive jurisdiction of the MTC. But as herein
before stated, the issue of title, ownership and/or possession thereof is intertwined with the issue of
annulment of sale and reconveyance hence within the ambit of the jurisdiction of the RTC. The assessed
value of the parcels of land thus becomes merely an incidental matter to be dealt with by the court,
when necessary, in the resolution of the case but is not determinative of its jurisdiction.
SPS HAGUETE v SPS EMBUDO
G.R. No. 149554. July 1, 2003
YNARES-SANTIAGO, J.:
FACTS:
Petitioners instituted against respondents a complaint filed before the RTC for the annulment of deed
of sale and partition plus damages. Petitioners alleged that their son-in-law, respondent Teofredo, sold
to them a 50-square meter portion of his 150-square meter parcel of land for P15,000.00; that Teofredo
acquired the lot from Ma. Lourdes Villaber-Padillo by virtue of a deed of sale, after which Transfer
Certificate of Title No. 99694 was issued solely in his name; that despite demands, Teofredo refused to
partition the lot between them. Petitioners prayed for partition, annulment of DoS and TCT and Tax
Dec in the name of Teofredo and new ones be issued in the name of the petitioners. Respondent filed
a Motion to Dismiss he complaint on the ground of lack of jurisdiction over the subject matter of the
case, arguing that the total assessed value of the subject land was only P15,000.00 which falls within
the exclusive jurisdiction MTC (Sec 33(3), BP129). Petitioners opposed contending that the action is
incapable of pecuniary estimation.
RTC dismissed the complaint for lack of jurisdiction. MR denied. Hence this petition.
ISSUE:
WON the action is incapable of pecuniary estimation.
HELD:
NO. Petitioners cause of action is based on their right as purchaser of the 50-square meter portion of
the land from respondents. They pray that they be declared owners of the property sold. Thus, their
complaint involved title to real property or any interest therein. The alleged value of the land which
they purchased was P15,000.00, which was within the jurisdiction of Municipal Trial Court. The
annulment of the deed of sale between Ma. Lourdes Villaber-Padillo and respondents, as well as of TCT
No. 99694, were prayed for in the complaint because they were necessary before the lot may be
partitioned and the 50-square meter portion subject thereof may be conveyed to petitioners.
Petitioners argument that the present action is one incapable of pecuniary estimation considering that
it is for annulment of deed of sale and partition is not well-taken. The nature of an action is not
determined by what is stated in the caption of the complaint but by the allegations of the complaint
and the reliefs prayed for. Where, as in this case, the ultimate objective of the plaintiffs 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.
The reliance of the petitioners on the case of Russell v. Vestil is misplaced. In the said case, petitioners sought the annulment of
the document entitled, Declaration of Heirs and Deed of Confirmation of Previous Oral Partition, whereby respondents declared
themselves as the only heirs of the late Spouses Casimero and Cesaria Tautho to the exclusion of petitioners. Petitioners brought
the action in order for them to be recognized as heirs in the partition of the property of the deceased. It was held that the action
to annul the said deed was incapable of pecuniary estimation and the consequent annulment of title and partition of the property
was merely incidental to the main action.