ORDINARY CIVIL ACTIONS

GR No. 149554
Spouses Huguete vs Spouses Embudo (July 01, 2003)

Facts
Petitioner spouses filed a complaint for the annulment of deed of sale and partition of the 50-
square meter portion of land against respondent spouses in the RTC.

Respondent spouses filed a Motion to Dismiss the complaint on the ground of lack of
jurisdiction over the subject matter of the case, arguing that the action is one for annulment of
title and the total assessed value of the subject land was only P15,000.00 which falls within the
exclusive jurisdiction of the MTC, pursuant to Sec 33(3) of BP Blg 129, as amended by RA 7691.

Petitioner spouses filed an Opposition to the Motion to Dismiss alleging that the subject matter
of the action is incapable of pecuniary estimation and, therefore, is cognizable by the RTC, as
provided by Sec 19(1) of BP 129, as amended.

Issue
WON the civil action is one in which the subject matter is incapable of pecuniary estimation.

Ruling
Motion for reconsideration and Petition for Review was denied.

Ratio
No. The 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.What determines the
nature of an action as well as which court has jurisdiction over it are the allegations of the
complaint and the character of the relief sought (Cañiza vs CA). Only those whose consideration
is 20,000.00 or more shall the RTC have cognizance of such subject matter. Thus, the price of
15,000.00 in this case falls within the jurisdiction of the MTC, METC, and MCTC.

GR No. 138248
Barangay Piapi vs Talip (Sept 07, 2009)

Facts

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.

RTC and SC Issue

Whether or not the Regional Trial Court has jurisdiction over the complaint for reconveyance.

RTC Ruling
The Trial Court dismissed the complaint for lack of jurisdiction

SC Ruling
The Supreme Court denied the Petition for Certiorari.

Ratio
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.