GR 158121; (December, 2007) (Digest)
G.R. No. 158121 ; December 12, 2007
HEIRS OF VALERIANO S. CONCHA, SR., petitioners, vs. SPOUSES GREGORIO J. LUMOCSO and BIENVENIDA GUYA, et al., respondents.
FACTS
The petitioners, heirs of spouses Valeriano Concha, Sr. and Dorotea Concha, filed three separate complaints for reconveyance and/or annulment of title against the respondents. The petitioners claimed ownership over specific lots (Lot No. 6195, a portion of Lot No. 6196-A, and a portion of Lot Nos. 6196-B and 7529-A) by virtue of their and their predecessors’ open, continuous, exclusive, and notorious possession since 1931, which they argued constituted a vested right under Section 48(b) of the Public Land Act ( Commonwealth Act No. 141 ). The respondents, however, are the registered patent holders and owners of these lots, holding original certificates of title issued by virtue of free patents.
The respondents filed motions to dismiss the complaints, arguing that the Regional Trial Court (RTC) lacked jurisdiction over the subject matter. They contended that since the petitioners’ cause of action was essentially for the recovery of ownership and possession based on their alleged prior possession, and the assessed value of each contested property was below the jurisdictional threshold, the cases fell within the exclusive original jurisdiction of the Municipal Trial Court (MTC) under Republic Act No. 7691 . The RTC denied the motions to dismiss, prompting the respondents to file a petition for certiorari with the Court of Appeals (CA). The CA granted the petition, annulled the RTC’s orders, and directed the dismissal of the complaints for lack of jurisdiction.
ISSUE
Whether the Regional Trial Court correctly exercised jurisdiction over the petitioners’ complaints for reconveyance and/or annulment of title.
RULING
No, the Regional Trial Court lacked jurisdiction. The Supreme Court affirmed the decision of the Court of Appeals. The Court held that jurisdiction is determined by the nature of the action and the allegations in the complaint. The petitioners’ actions, although styled as ones for reconveyance and annulment of title, were fundamentally actions for recovery of ownership and possession based on their claim of a vested right under Section 48(b) of the Public Land Act. The core relief sought was a declaration that the lots were their private property due to acquisitive prescription, and for the respondents to reconvey these properties.
Crucially, the Court ruled that where the assessed value of the real property subject of the litigation is alleged to be below the jurisdictional amount (P20,000.00 outside Metro Manila at the time), and the action does not involve the direct attack of a patent or title for being void ab initio on grounds of fraud, the case falls within the exclusive original jurisdiction of the Municipal Trial Court under Republic Act No. 7691 . The petitioners’ claim that the respondents’ titles were void was a mere consequence of their assertion of ownership by prescription, not a direct challenge based on specific grounds like the respondents’ disqualification to apply for a patent. Therefore, since the complaints principally aimed to recover title and possession based on the value of the property, and the assessed values were below the RTC threshold, the MTC had exclusive original jurisdiction. The RTC’s denial of the motions to dismiss was a grave abuse of discretion.