Copioso vs Copioso

GR No. 149243
October 28, 2002

Facts:

Respondents filed with the RTC an action for specific performance of reconveyance
of two parcels of land having an assessed value of P3,770.00. Respondents alleged
that they together with their deceased brother were co-owners of the subject
property having inherited the same from their parents, and that through fraud and
machination the deceased had the property transferred to his name and that of
spouses Doria who subsequently sold the same to third parties.  Thus, they are
praying for the reconveyance of the property by virtue of their being co-owners
thereof. Petitioners, however, moved to dismiss the complaint on that ground that it
was the MTC and not the RTC that had jurisdiction considering that the assessed
value of the property was lower than P20,000.00 (Section 33 [3]
of Batas Pambansa Blg. 129, as amended by R.A. No. 7691). Petitioners argue that
the complaint for reconveyance cannot be resolved unless the trial court delves
upon the issues of “title, possession and interests” of each of the stakeholders over
the subject parcels of land.

Respondents , on the other hand, claim that the instant complaint for reconveyance
is a case of joinder of causes of action which include the annulment of sale and
other instruments of false conveyance incapable of pecuniary estimation thus within
the legal competence of the RTC ( Section 19(l) of B.P. 129, as amended). The trial
court denied the motion to dismiss holding that since the subject matter of the
action was beyond pecuniary estimation it was properly within its jurisdiction.

Issue:

Whether or not denial of the motion to dismiss was correct.

Held:

Yes.
Although the assessed value of the two parcels of land involved is P3,770.00, which
is within the jurisdiction of the MTC, the action filed by the respondents is for
specific performance of reconveyance, annulment of contracts and claim for
damages, which are incapable of pecuniary estimation and thus properly within the
jurisdiction of the RTC.

If the action affects the title to or possession of real property then it is a real action
and jurisdiction is determined by the assessed value of the property. It is within the
jurisdiction therefore of the Metropolitan Trial Court.