G.R. No. 208232 , March 10, 2014
SURVIVING HEIRS OF ALFREDO R. BAUTISTA, namely: EPIFANIA G. BAUTISTA and ZOEY G. BAUTISTA, Petitioners, vs. FRANCISCO LINDO and WELHILMINA LINDO; and HEIRS OF FILIPINA DAQUIGAN, namely: MA. LOURDES DAQUIGAN, IMELDA CATHERINE DAQUIGAN, IMELDA DAQUIGAN and CORSINO DAQUIGAN, REBECCA QUIAMCO and ANDRES QUIAMCO, ROMULO LORICA and DELIA LORICA, GEORGE CAJES and LAURA CAJES, MELIDA BANEZ and FRANCISCO BANEZ, MELANIE GOFREDO, GERVACIO CAJES and ISABEL CAJES, EGMEDIO SEGOVIA and VERGINIA SEGOVIA, ELSA N. SAM, PEDRO M. SAM and LINA SAM, SANTIAGO MENDEZ and MINA MENDEZ, HELEN M. BURTON and LEONARDO BURTON, JOSE JACINTO and BIENVENIDA JACINTO, IMELDA DAQUIGAN, LEO MATIGA and ALICIA MATIGA, FLORENCIO ACEDO JR., and LYLA VALERIO, Respondents.

FACTS

Alfredo R. Bautista inherited a free-patent land in 1983, covered by OCT No. (1572) P-6144. In 1991, he subdivided and sold the property to several vendees (respondents) via a notarized deed of absolute sale. Subsequently, OCT No. (1572) P-6144 was canceled and TCTs were issued in favor of the vendees. On August 5, 1994, Bautista filed a complaint for repurchase against respondents before the RTC, anchoring his cause on Section 119 of Commonwealth Act No. 141 (Public Land Act), which grants a right of repurchase within five years from the date of conveyance. During the pendency, Bautista died and was substituted by petitioner Epifania G. Bautista. Respondents Francisco and Welhilmina Lindo entered into a compromise agreement with petitioners, which was approved by the RTC in a 2011 Decision. Other respondents filed a Motion to Dismiss in 2013, alleging the complaint failed to state the value of the property sought to be recovered and that the total selling price was only PhP 16,500, thus claiming the RTC had no jurisdiction as the assessed value was below the PhP 20,000 jurisdictional ceiling for real actions under BP 129. The RTC granted the motion and dismissed the complaint for lack of jurisdiction, finding Bautista failed to allege the property value exceeded PhP 20,000 and that the stated total refund was PhP 16,500.

ISSUE

Whether or not the RTC erred in granting the motion for the dismissal of the case on the ground of lack of jurisdiction over the subject matter.

RULING

Yes, the RTC erred. The Supreme Court ruled the petition meritorious. The action filed by petitioners to enforce the right to repurchase under Section 119 of CA 141 is a civil action incapable of pecuniary estimation, specifically one for specific performance. Jurisdiction is determined by the allegations in the complaint and the character of the relief sought. Where the basic issue is other than the right to recover a sum of money, and the money claim is incidental to the principal relief, the action is incapable of pecuniary estimation and cognizable exclusively by RTCs under BP 129, Sec. 19(1). The right to repurchase is a binding prestation deemed integrated into the deed of sale by operation of law, which Bautista sought to enforce. Therefore, the RTC had jurisdiction regardless of the property’s value. The Supreme Court REVERSED and SET ASIDE the RTC’s Orders and ordered the RTC to proceed with resolving the case.