GR 181622; (November, 2013) (Digest)
G.R. No. 181622 ; November 20, 2013
GENESIS INVESTMENT, INC., CEBU JAYA REALTY INC., and SPOUSES RHODORA and LAMBERT LIM, Petitioners, vs. HEIRS of CEFERINO EBARASABAL, et al., Respondents.
FACTS
The respondents, heirs of Roman Ebarasabal, filed a Complaint for Declaration of Nullity of Documents, Recovery of Shares, Partition, Damages and Attorney’s Fees against the petitioners. The complaint alleged that the petitioners fraudulently obtained titles over a parcel of land in Moalboal, Cebu, originally owned by Roman Ebarasabal, through simulated deeds of sale and falsified documents. The assessed value of the property was admitted to be Php 11,990.00. The petitioners moved to dismiss the case, contending that since the action involved title to or interest in real property with an assessed value below Php 20,000.00, jurisdiction belonged to the Municipal Trial Court (MTC) and not the Regional Trial Court (RTC).
The RTC initially granted the motion to dismiss, agreeing that the case involved title to real property and its assessed value placed it under MTC jurisdiction. Upon reconsideration, however, the RTC reversed itself, holding that the principal action was for the annulment of documents, which is incapable of pecuniary estimation and thus within RTC jurisdiction, with the issues of title and possession being merely incidental. The Court of Appeals affirmed this ruling, prompting the petitioners to elevate the case to the Supreme Court.
ISSUE
Whether the Regional Trial Court has jurisdiction over the complaint, considering the property’s assessed value is below the jurisdictional threshold for MTCs.
RULING
Yes, the Regional Trial Court has jurisdiction. The Supreme Court affirmed the rulings of the RTC and the Court of Appeals. The Court reiterated the well-settled doctrine that jurisdiction is determined by the nature of the action as alleged in the complaint and the primary relief sought. An action for annulment of documents, such as deeds of sale, is inherently incapable of pecuniary estimation. The value of the property subject of the annulled documents does not alter this nature.
In this case, the respondents’ primary objective was to nullify the documents through which the petitioners allegedly derived their claim. The core issue was the validity of these instruments, not merely the recovery of property. While the resolution of this issue would necessarily affect title to the land, this consequence is incidental to the principal action for annulment. Therefore, the case falls under the exclusive original jurisdiction of the RTC over actions incapable of pecuniary estimation, pursuant to Section 19(1) of Batas Pambansa Blg. 129, as amended. The assessed value of the property becomes irrelevant for jurisdictional purposes when the main action is of such nature. The petition was denied for lack of merit.