G.R. No. 181303 ; September 17, 2009
Carmen Danao Malana, et al. vs. Benigno Tappa, et al.

FACTS

Petitioners, heirs of Anastacio Danao, filed a Complaint for Reivindicacion, Quieting of Title, and Damages before the Regional Trial Court (RTC) against respondents. They alleged ownership of a parcel of land in Tuguegarao City covered by TCT No. T-127937, inherited from Anastacio. They claimed that respondents, family members of a previous occupant permitted by Anastacio to occupy a portion, had refused to vacate and were asserting ownership based on allegedly dubious documents, creating a cloud on petitioners’ title. Petitioners sought recovery of possession, quieting of title, and various damages.
The RTC, before respondents could answer, issued an Order dismissing the Complaint for lack of jurisdiction. The court found the action to be a real action involving property with an assessed value of only ₱410.00. Citing Republic Act No. 7691 , it ruled that exclusive original jurisdiction over such real actions where the assessed value does not exceed ₱20,000.00 lies with the Municipal Trial Court (MTC). Petitioners’ motion for reconsideration was denied, with the RTC rejecting their argument that an action for quieting of title is within RTC jurisdiction under Rule 63, holding that such an action remains a real action subject to the jurisdictional threshold.

ISSUE

Whether the Regional Trial Court correctly dismissed the Complaint for lack of jurisdiction.

RULING

Yes, the RTC correctly dismissed the Complaint. The Supreme Court affirmed that the nature of an action—whether real or personal—is determined by the allegations in the complaint and the primary relief sought. A real action is one where the plaintiff seeks to recover title to, possession of, or any interest in real property. Petitioners’ core prayer was for recovery of ownership and possession of the land (reivindicacion) and the removal of a cloud on their title (quieting of title). Both are inherently real actions because they directly affect title to and interest in the property.
Consequently, jurisdiction is governed by Section 19(2) of Batas Pambansa Blg. 129, as amended by R.A. No. 7691 , which mandates that the MTC has exclusive original jurisdiction over real actions where the assessed value of the property does not exceed ₱20,000.00. The assessed value of the subject property was a mere ₱410.00, far below the threshold. The Court clarified that Rule 63 on quieting of title does not confer jurisdiction but merely provides the procedural rule for an action that is substantive in nature. Jurisdiction is conferred by law. Since the law vests jurisdiction over this low-value real action in the MTC, the RTC committed no grave abuse of discretion in dismissing the case. The inclusion of a claim for damages, being merely incidental to the real action, did not alter the nature of the case or vest jurisdiction in the RTC.