G.R. No. 149243 October 28, 2002
LOLITA B. COPIOSO, petitioner, vs. LAURO, DOLORES, RAFAEL, ESTEBAN, and CORAZON, all surnamed COPIOSO, and COURT OF APPEALS, respondents.

FACTS

Respondents Lauro, Dolores, Rafael, Esteban, and Corazon Copioso filed a complaint for reconveyance of two parcels of coconut land in Laguna against petitioner Lolita B. Copioso, spouses Bernabe and Imelda Doria, the estate of deceased Antonio Copioso, and several vendees. Respondents alleged they were co-owners of the property, having inherited it from their parents, and that through fraud, their deceased brother Antonio had the property transferred to his name and to the Dorias, who subsequently sold portions to third parties. When respondents stated the assessed value of the property was P3,770.00, petitioner and the Doria spouses moved to dismiss the complaint, arguing that the Municipal Trial Court (MTC), not the Regional Trial Court (RTC), had jurisdiction since the assessed value was below P20,000.00. The RTC denied the motions to dismiss, ruling the action was beyond pecuniary estimation and within its jurisdiction. The Court of Appeals affirmed the RTC’s jurisdiction, prompting this petition.

ISSUE

Whether the Regional Trial Court (RTC) or the Municipal Trial Court (MTC) has jurisdiction over the complaint for reconveyance, considering the assessed value of the subject property is below P20,000.00.

RULING

The Supreme Court ruled that the RTC has jurisdiction. The complaint, titled “Reconveyance and/or Recovery of Common Properties Illegally Disposed, with Annulment of Sales and other Instruments of False Conveyance, with Damages, and Restraining Order,” constitutes a joinder of causes of action. It involves not merely issues of title, possession, or interest in real property, but also includes actions to annul contracts, for reconveyance or specific performance, and claims for damages (including moral, exemplary damages, and attorney’s fees totaling approximately P286,500.00). These aspects are incapable of pecuniary estimation, which, under Section 19(1) of B.P. Blg. 129, as amended, falls within the exclusive original jurisdiction of the RTC. While the assessed value of the property would typically place an action involving only title or possession under MTC jurisdiction per Section 33(3), here, the assessed value is merely incidental and not determinative of jurisdiction because the core issues are intertwined with actions incapable of pecuniary estimation. Therefore, the petition was denied, and the Decision and Resolution of the Court of Appeals were affirmed.