GR 138248 Sept 7, 2005

BRGY PIAPI vs TALIP

FACTS:
(A petition for review on certiorari assailing 3 orders of the RTC)
Petitioners filed with RTC a complaint for reconveyance and damages with prayer for issuance of a
temporary restraining order and/or writ of preliminary injunction against respondent.
The complaint alleges that petitioners and their predecessors-in-interest have been in actual,
peaceful, continuous, and open possession for over 30 years of a parcel of land. Said land was
covered by an OCT issued in the name of Juan Jayag. Petitioners built houses thereon and on the
remaining portion were constructed their barangay center, gym, and health center. Respondent
fraudulently obtained from said Registry of Deed a Transfer Certificate of Title in his name, and
later threatened to fence said land.
Respondent moved to dismiss the complaint contending that RTC had no jurisdiction over the case.
Petitioners opposed, but RTC subsequently ruled to dismiss the complaint for lack of jurisdiction.
Motion for reconsideration was denied. Hence, this petition.
ISSUE: WON RTC has the jurisdiction over the complaint for reconveyance since it is incapable of
pecuniary estimation
HELD:
NO. The petition is bereft of merit. In Huguete vs Embudo, we ruled that 'the nature of an action is
not determined by what is stated in the caption of the complaint but by the allegations of the
complaint and the reliefs prayed for. Where the ultimate objective of the plaintiffs, like
petitioners herein, is to obtain title to real property, it should be filed in the proper court having
jurisdiction over the assessed value of the property subject thereof.
Indeed, basic as a hornbook principle is that the nature of an action, as well as which court or body
has jurisdiction over it, is determined based on the allegations contained in the complaint of the
plaintiff, irrespective of whether or not the plaintiff is entitled to recover upon all or some of the
claims asserted therein.
The Rule requires that 'the assessed value of the property, or if there is none, the estimated value
thereof, shall be alleged by the claimant. Considering that their action involves the title to or
interest in real property, they should have alleged therein its assessed value. However, they only
specified the market value or estimated value, which is P 15,000.00. Pursuant to the provision of
Section 33 (3) quoted earlier, it is the Municipal Circuit Trial Court of Padada-Kiblawan, Davao del
Sur, not the RTC, which has jurisdiction over the case.