GR 149554; (July, 2003) (Digest)
G.R. No. 149554 ; July 1, 2003
SPOUSES JORGE J. HUGUETE and YOLANDA B. HUGUETE, petitioners, vs. SPOUSES TEOFEDO AMARILLO EMBUDO and MARITES HUGUETE-EMBUDO, respondents.
FACTS
Petitioners, spouses Jorge and Yolanda Huguete, filed a complaint against respondents, their son-in-law and daughter, before the Regional Trial Court (RTC) of Cebu. They alleged that in 1995, they paid respondent Teofredo Embudo P15,000.00 for a 50-square meter portion of his 150-square meter lot, built a house thereon, and demanded partition. They discovered that Teofredo had secured a Deed of Sale and a Transfer Certificate of Title (TCT No. 99694) for the entire lot solely in his name. The complaint prayed for annulment of the deed of sale and TCT, partition of the lot, and the issuance of separate titles.
Respondents moved to dismiss the complaint for lack of jurisdiction, arguing that the assessed value of the property was only P15,000.00, which falls under the exclusive original jurisdiction of the Municipal Trial Court (MTC) pursuant to Section 33(3) of Batas Pambansa Blg. 129, as amended. Petitioners opposed, contending that their action for annulment of documents and partition was incapable of pecuniary estimation and thus within the RTC’s jurisdiction under Section 19(1). The RTC granted the motion to dismiss, prompting this petition.
ISSUE
Whether the Regional Trial Court has jurisdiction over the complaint, or if jurisdiction properly lies with the Municipal Trial Court based on the assessed value of the property.
RULING
The Supreme Court denied the petition and affirmed the RTC’s dismissal for lack of jurisdiction. The Court held that jurisdiction is determined by the allegations in the complaint and the character of the relief sought. While the complaint was captioned as one for “Annulment” and “Partition,” a scrutiny of its allegations and prayer revealed that the core objective was to recover title to, or possession of, a specific portion of real property. The annulment of the deed of sale and the TCT were merely incidental to this primary goal of establishing ownership over the 50-square meter lot.
Consequently, the action was essentially a real action. Under Section 33(3) of B.P. 129, as amended, MTCs have exclusive original jurisdiction over actions involving title to or possession of real property where the assessed value does not exceed P20,000.00 (P50,000.00 in Metro Manila). The assessed value of the subject property, as stated in the complaint, was P15,000.00. Therefore, jurisdiction vested in the MTC, not the RTC. The Court rejected the argument that the action was incapable of pecuniary estimation, reiterating that where the ultimate relief is a claim over real property, the assessed value governs jurisdictional determination.