GR 238805; (September, 2020) (Digest)
G.R. No. 238805 , September 23, 2020
SPOUSES JIMMY M. LIU & EMILE L. LIU, PETITIONERS, VS. COURT OF APPEALS, REGIONAL TRIAL COURT, BRANCH 17 (DAVAO CITY) PRESIDING JUDGE AND ALVIN CRUZ, RESPONDENTS.
FACTS
Petitioners, the registered owners of a parcel of land in Davao City, discovered their owner’s duplicate certificate of title was missing. Upon reporting the loss, they found that a forged Affidavit of Recovery and Special Power of Attorney had been annotated on the title, leading to an Absolute Deed of Sale conveying the property to respondent Alvin Cruz. Petitioners filed a complaint for recovery of real property (accion reivindicatoria), reconveyance, and declaration of nullity of the said documents and Cruz’s title, alleging forgery and non-receipt of any sale proceeds.
During trial, respondent Cruz moved to dismiss the case for lack of jurisdiction, arguing that the assessed value of the property was only P19,840.00, which falls below the jurisdictional threshold for the Regional Trial Court (RTC). The RTC denied the motion. On certiorari, the Court of Appeals reversed the RTC, holding that jurisdiction lay with the Municipal Trial Court (MTC) based on the property’s assessed value.
ISSUE
Whether the Court of Appeals erred in ruling that the RTC lacked jurisdiction over the complaint for recovery of title and possession, annulment of documents, and reconveyance.
RULING
The Supreme Court dismissed the petition and affirmed the CA’s decision. The Court held that while the complaint included prayers for annulment of documents, its ultimate objective was to recover ownership and possession of the real property. Jurisdiction over actions involving title to or possession of real property is determined by the assessed value of the property pursuant to Section 19(2) of Batas Pambansa Blg. 129, as amended by Republic Act No. 7691 . The law divides original jurisdiction between first-level courts (MTCs) and second-level courts (RTCs) using the assessed value as the benchmark. Since the petitioners’ complaint explicitly stated the assessed value was P19,840.00, which is below the jurisdictional amount for the RTC, the MTC properly had exclusive original jurisdiction. The nature of the action is not one incapable of pecuniary estimation because the core relief sought is recovery of real property, the value of which is quantifiable through its assessed value for jurisdictional purposes.