G.R. No. 138248. September 7, 2005.
BARANGAY PIAPI, represented by its chairman ANDRES L. LUGNASIN, et al., Petitioners, vs. IGNACIO TALIP representing the HEIRS OF JUAN JAYAG, Respondent.

FACTS

Petitioners, Barangay Piapi and several residents, filed a complaint for reconveyance and damages with the Regional Trial Court (RTC) of Digos, Davao del Sur. They alleged that they and their predecessors-in-interest had been in open, continuous, and peaceful possession for over 30 years of a 3.2-hectare parcel of land covered by Original Certificate of Title (OCT) No. P-(3331)-4244 in the name of Juan Jayag. They built houses, a barangay center, a gym, and a health center on the land. They claimed that respondent Ignacio Talip, representing Jayag’s heirs, fraudulently obtained a Transfer Certificate of Title (TCT) in his name, paid real estate taxes in 1998, and threatened to fence the property.
Instead of filing an answer, respondent moved to dismiss the complaint on the ground of lack of jurisdiction. He argued that under Section 33(3) of Batas Pambansa Blg. 129, as amended by Republic Act No. 7691, the case fell within the exclusive original jurisdiction of the Municipal Circuit Trial Court (MCTC) because the assessed value of the property was only ₱6,030.00. Petitioners opposed, contending that the RTC had jurisdiction because the action was incapable of pecuniary estimation and, alternatively, that the total assessed value was ₱41,890.00 per a Provincial Assessor’s sheet.

ISSUE

Whether the Regional Trial Court correctly dismissed the complaint for lack of jurisdiction over the subject matter.

RULING

Yes, the Supreme Court affirmed the RTC’s dismissal. The Court held that jurisdiction is determined by the allegations in the complaint and the reliefs sought, not by the caption or the plaintiff’s characterization. Examining the complaint, the ultimate objective was to recover title to and possession of real property, as petitioners sought reconveyance based on alleged fraud and their long-term possession. Therefore, the action involved title to or interest in real property.
For such actions, jurisdiction between the RTC and inferior courts is determined by the assessed value of the property. Section 19(2) of B.P. Blg. 129, as amended, grants RTCs exclusive original jurisdiction only where the assessed value exceeds ₱20,000.00. Petitioners’ complaint failed to allege the assessed value. It only stated the market value of ₱15,000.00. Under Section 33(3), the MCTC has exclusive original jurisdiction where the assessed value does not exceed ₱20,000.00, or, if the land is undeclared for taxation, where the value as determined does not exceed that threshold. Since the complaint alleged a market value below ₱20,000.00 and no assessed value, jurisdiction properly vested with the MCTC of Padada-Kiblawan, not the RTC. The petition was denied.