G.R. No. 217755, September 18, 2019
Elmer Montero, Petitioner, vs. Santiago Montero, Jr. and Charlie Montero, Respondents.

FACTS

Petitioner Elmer Montero filed a Complaint before the Regional Trial Court (RTC) of Bangued, Branch 2, against respondents Santiago Montero, Jr. and Charlie Montero, among others. The Complaint sought the Declaration of Nullity of an Affidavit of Adjudication, Cancellation of Tax Declaration No. 5289 and Original Certificate of Title (OCT) No. P-14452, Reconveyance, and Damages with Prayer for Preliminary Injunction. Elmer alleged that the subject property, a parcel of land in Pilar, Abra, was originally owned by Dominga Taeza, who died intestate in 1975. He claimed to be a surviving heir of Dominga’s son, Alfredo Montero. He asserted that in 1993, he discovered the property had been transferred to respondent Santiago Montero, Jr.’s name via an Affidavit of Adjudication dated June 13, 1989, based on Santiago’s misrepresentation that he was the sole heir of his father, Santiago Montero, Sr., who was Dominga’s stepson (being the son of Jose Montero by a first marriage). By virtue of this affidavit, Tax Declaration No. 417 in Dominga’s name was cancelled and replaced by Tax Declaration No. 5289 in Santiago’s name, and OCT No. P-14452 was issued in his name. Elmer further alleged that in 2002, the respondents threatened physical harm and began construction on the land. The respondents filed a Motion to Dismiss, arguing the RTC lacked jurisdiction because the assessed value of the property was P3,010.00, which did not exceed P20,000.00, thus placing exclusive original jurisdiction with the Municipal Trial Court under BP 129. They also contended the action constituted an impermissible collateral attack on a Torrens title. The RTC denied the motion, ruling the cause of action was incapable of pecuniary estimation and involved a direct attack on the title. The Court of Appeals (CA) granted the respondents’ petition, set aside the RTC orders, and dismissed the case for lack of jurisdiction, holding that the action involved title to or possession of real property, and with the assessed value below P20,000.00, jurisdiction belonged to the inferior courts.

ISSUE

Whether the subject matter of petitioner Elmer Montero’s Complaint involves title to, possession of, or interest in real property (with its assessed value determining jurisdiction) or is an action incapable of pecuniary estimation (falling under RTC jurisdiction).

RULING

The Supreme Court DENIED the petition and AFFIRMED the CA Decision and Resolution. The Court ruled that petitioner Elmer’s Complaint involved title to, possession of, and interest in real property. Jurisdiction is determined by the allegations in the complaint and the principal relief sought. Although the complaint was captioned as one for declaration of nullity of documents and reconveyance, its ultimate objective, as stated in the complaint itself, was to compel the respondents “to respect the right of ownership and possession over the land” and to establish Elmer’s “rightful ownership.” The primary relief sought was the establishment and confirmation of Elmer’s right of ownership and possession against the respondents. The cancellation of the Affidavit of Adjudication, Tax Declaration, and OCT would merely be a necessary consequence of resolving the ownership issue. Therefore, the action was one involving title to or possession of real property. Since the assessed value of the property was undisputedly P3,010.00 (below the P20,000.00 threshold under BP 129, as amended), exclusive original jurisdiction was vested in the Metropolitan Trial Courts, Municipal Trial Courts, or Municipal Circuit Trial Courts, not the RTC. The RTC thus had no jurisdiction to hear the case.