1. Gomez vs.

Montalban GR 174414 (March 14,2008) — In all other cases in which the demand, exclusive of interest,
damages of whatever kind, attorney's fees, litigation expenses, and costs or the value of the property in controversy
exceeds…
FACTS:
 Petitioner filed a Complaint with the RTC for a sum of money, damages and payment of attorney's fees
against respondent. The Complaint alleged, among other things, that: respondent obtained a loan from
petitioner in the sum of P40,000.00 with a voluntary proposal on her part to pay 15% interest per month;
upon receipt of the proceeds of the loan, respondent issued in favor of petitioner, as security, Capitol Bank
Check No. 0215632 in the sum of P46,000.00, covering the P40,000.00 principal loan amount and P6,000.00
interest charges for one month; when the check became due, respondent failed to pay the loan despite
several demands; thus, petitioner filed the Complaint praying for the payment of P238,000.00, representing
the principal loan and interest charges, plus 25% of the amount to be awarded as attorney's fees, as well as
the cost of suit.
 After considering the evidence presented by petitioner, the RTC rendered a Decision in his favor and ordered
the respondent to pay the petitioner the following amounts:
1. P40,000.00 representing the principal amount of the loan;
2. P57,600.00 representing interest at the rate of 24% per annum reckoned from August 26, 1998 until
the present;
3. P15,000.00 representing attorney's fees.
ISSUE:
 Whether or not the Regional Trial Court has jurisdiction over the case for sum of money, damages and
attorney's fees where the principal amount of the obligation is P40,000.00 but the amount of the demand
per allegation of the complaint is P238,000.00?
RULING:
 Yes, the RTC has jurisdiction over the case.
 It is irrelevant that during the course of the trial, it was proven that respondent is only liable to petitioner for
the amount of P40,000.00 representing the principal amount of the loan; P57,000.00 as interest thereon at
the rate of 24% per annum; and P15,000.00 as attorney's fees. Contrary to respondent's contention,
jurisdiction can neither be made to depend on the amount ultimately substantiated in the course of the trial
or proceedings nor be affected by proof showing that the claimant is entitled to recover a sum in excess of
the jurisdictional amount fixed by law. Jurisdiction is determined by the cause of action as alleged in the
complaint and not by the amount ultimately substantiated and awarded.
 Jurisdiction over the subject matter of a case is conferred by law and determined by the allegations in the
complaint which comprise a concise statement of the ultimate facts constituting the plaintiff's cause of
action. 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 averments in the complaint and the
character of the relief sought are the ones to be consulted. Once vested by the allegations in the complaint,
jurisdiction also remains vested irrespective of whether or not the plaintiff is entitled to recover upon all or
some of the claims asserted therein.

2. Soriano vs Omila L-7112 May 21,1955 – TOTALITY OF DEMAND DETERMINES JURISDICTION OF COURTS
FACTS:
 Petitioner brought an action to recover from the defendant the following: P300 on the first cause of action,
for a promissory note executed by defendant and appellant in favor of plaintiff and appellee; P700 on the
second cause, for another promissory note; P3,000 on the third cause, as moral damages for derogatory
remarks made against the personality of plaintiff and appellee in a letter to the latter’s counsel; and P600 as
attorney’s fees.
 In his answer, the respondent, alleged: that the sums claimed in the first and second causes of action have
already been paid; that the supposed derogatory remarks, basis of third cause, have not been motivated by
ill will or a desire to besmirch the name and personality of the plaintiff. By way of counterclaim, he
 demanded P1,683 as commissions, and P4,200 as moral damages for the filing of the suit, and P1,000 as
attorney’s fees.
 The Court of First Instance rendered judgment in favor of the petitioner and against respondent for the sums
of P300 and P700 (demanded in the first and second causes of action.) The claims made in the third and
fourth causes of action were dismissed, on the ground that there is no sufficient evidence to establish the
claim of petitioner with regard to the moral and exemplary damages.
 The respondent presented a motion for reconsideration, alleging that the court had no jurisdiction over the
subject matter of the first, second and fourth causes of action. However, the motion was denied.
ISSUE:
 Whether or not the Court of First Instance has jurisdiction over the case?
RULING:
 Yes, the Court of First Instance has jurisdiction over the case.
 The jurisdiction of the court has always been based on the amount of the demand.
 The jurisdiction of a court is made to depend, not upon the value or demand in each single cause of action
contained in the complaint, but upon the totality of the demand in all the causes of action. In Gutierrez v.
Ruiz 94 Phil., 1024 50 Off. Gaz., 2480, the Court held that the aggregate amount of the demand, P2,700
(P2,000 and P700), brought the action under the jurisdiction of the court of first instance. The practice has
always been to attend to the total amount demanded in the complaint, especially in the prayer, as
determinative of the jurisdiction of the court. The claim of the respondent that as the court has no
jurisdiction of each of the amounts demanded in the first, second and fourth causes of action, it has no
jurisdiction of the action, must therefore be overruled.
 The demand is not a fictitious demand; the trial court denied the claim for P3,000, not on the ground that it
was unfounded and fictitious, but on the ground that no sufficient evidence was given to support the same.
Under the circumstances, therefore, the amount demanded in the third cause of action, P3,000, should be
included in the determination of the total amount of the demand. With this claim for P3,000 the aggregate
amount demanded is P4,600, which is far above the amount fixed as a minimum for the trial court’s
jurisdiction.

3. Russell vs. Vestil GR 119437 (Mar. 17,1999) – CASES OF CAPABLE PECUNIARY INTEREST
FACTS:
 The petitioners filed a complaint against private respondents, denominated "Declaration of Nullity And
Partition," with the Regional Trial Court of Mandaue City. The complaint, in substance, alleged that
petitioners are co-owners of a parcel of land situated in Liloan, Cebu. The land was previously owned by the
spouses Casimero Tautho and Cesaria Tautho. Upon the death of said spouses, the property was inherited by
their legal heirs, herein petitioners and private respondents. Since then, the lot had remained undivided until
petitioners discovered a public document denominated "Declaration of Heirs And Deed Of Confirmation of a
Previous Oral Agreement of Partition,". By virtue of this deed, private respondents divided the property
among themselves to the exclusion of petitioners who are also entitled to the said lot as heirs of the late
spouses Casimero Tautho and Cesaria Tautho. Petitioners claimed that the document was false and
perjurious as the private respondents were not the only heirs and that no oral partition of the property
whatsoever had been made between the heirs. The complaint prayed that the document be declared null
and void and an order be issued to partition the land among all the heirs.
 Private respondents filed a Motion to Dismiss the complaint on the ground of lack of jurisdiction over the
nature of the case as the total assessed value of the subject land is P5,000.00 which under section 33 (3)3 of
Batas Pambansa Blg. 129, as amended by R.A. No. 7691, falls within the exclusive jurisdiction of the
Municipal Circuit Trial Court of Liloan, Compostela.
 Petitioners filed an Opposition to the Motion to Dismiss saying that the Regional Trial Court has jurisdiction
over the case since the action is one which is incapable of pecuniary estimation within the contemplation of
Section 19(l) of B.P. 129, as amended.
 The respondent judge issued an Order granting the Motion to Dismiss. A Motion for Reconsideration of said
order was filed by petitioners alleging that the same is contrary to law because their action is not one for
 recovery of title to or possession of the land but an action to annul a document or declare it null and void,
hence, one incapable of pecuniary estimation failing within the jurisdiction of the Regional Trial Court.
 The respondent judge issued another Order denying the motion for reconsideration.
ISSUE:
 Whether or not the RTC has jurisdiction over the case?
RULING:
 Yes, the RTC has jurisdiction over the case.
 The complaint filed before the Regional Trial Court is doubtless one incapable of pecuniary estimation and
therefore within the jurisdiction of said court.
 In Singsong vs. Isabela Sawmill, the Court held that:
In determining whether an action is one the subject matter of which is not capable of pecuniary estimation
the Court has adopted the criterion of first ascertaining the nature of the principal action or remedy sought.
If it is primarily for the recovery of a sum of money, the claim is considered capable of pecuniary estimation,
and whether jurisdiction is in the municipal courts or in the courts of first instance would depend on the
amount of the claim. However, where the basic issue is something other than the right to recover a sum of
money, where the money claim is purely incidental to, or a consequence of, the principal relief sought, the
Court has considered such actions as cases where the subject of the litigation may not be estimated in terms
of money, and are cognizable exclusively by courts of first instance (now Regional Trial Courts).
 The main purpose of petitioners in filing the complaint is to declare null and void the document in which
private respondents declared themselves as the only heirs of the late spouses Casimero Tautho and Cesaria
Tautho and divided his property among themselves to the exclusion of petitioners who also claim to be legal
heirs and entitled to the property. While the complaint also prays for the partition of the property, this is just
incidental to the main action, which is the declaration of nullity of the document above-described. It is
axiomatic that jurisdiction over the subject matter of a case is conferred by law and is determined by the
allegations in the complaint and the character of the relief sought, irrespective of whether the plaintiff is
entitled to all or some of the claims asserted therein.

4. Booking vs. CA G.R. No. 161739 May 4, 2006 – CASES OF CAPABLE PECUNIARY INTEREST
FACTS:
 The respondents filed a complaint against the heirs of Miguel Bokingo which included petitioner Alfredo
Bokingo with the Regional Trial Court of Butuan City and prayed to enjoin permanently the illegal acts of the
such heirs and the petitioner of preventing the survey of the parcel of land which were inherited by the
respondents from their father, to order them to pay the respondents the sum of P10,000.00 as attorney’s
fees, and P10,000.00 as litigation expenses, and to pay damages to the respondents.
 Petitioner Bokingo filed with the court a quo a motion to dismiss alleging that the latter has no jurisdiction
over the subject matter of the claim. Specifically, petitioner Bokingo contended that it could be gleaned from
the complaint that the issue between the parties involved the possession of the land. As such, the assessed
value of the land was crucial to determine the court’s jurisdiction over the subject matter. If the assessed
value thereof is P20,000.00 or less, then the Municipal Trial Court has jurisdiction over the subject matter.
Otherwise, jurisdiction is with the RTC.
 Petitioner Bokingo pointed out in his Motion to Dismiss that the assessed value of the land subject matter of
the complaint was not indicated. Nonetheless, he proffered that based on his father’s tax declaration
covering the subject land, its assessed value was only P14,410.00. Consequently, it was allegedly clear that
the court a quo, a Regional Trial Court, had no jurisdiction over the subject matter of the complaint filed by
the respondents. Rather, in view of the assessed value of the subject land which was allegedly less than the
P15,000.00, jurisdiction properly belonged to the MTC.
 However, the petitioner’s motion to dismiss was denied by the RTC. It pointed out that the complaint’s
allegation is that the respondents are entitled to have the subject land surveyed after petitioner Bokingo’s
and his co-claimants’ application for the titling of the subject land was dismissed by the Provincial
Environment and Natural Resources Officer and the respondents were declared to have a better right to file
a public land application covering the same. Further, the relief being sought in the complaint is injunction in
order that the respondents’ right to survey the subject land would not be defeated.
  Petitioner Bokingo filed with the Court of Appeals a petition for certiorari alleging grave abuse of discretion
on the part of the RTC in denying his motion to dismiss but the CA dismissed his petition for lack of merit, in
fact and in law.
ISSUE:
 Whether or not the RTC has jurisdiction over the case?
RULING:
 Yes, the RTC has jurisdiction over the case.
 The present petition lacks substantive merit. It is axiomatic that the nature of the action and which court has
original and exclusive jurisdiction over the same is determined by the material allegations of the complaint,
the type of relief prayed for by the plaintiff, and the law in effect when the action is filed, irrespective of
whether the plaintiffs are entitled to some or all of the claims asserted therein. The caption of the complaint
is not determinative of the nature of the action nor does the jurisdiction of the court depend upon the
answer of the defendant or agreement of the parties, or to the waiver or acquiescence of the parties.
 The complaint of the respondents shows that it alleges that per the Order of PENRO of Butuan City,
petitioner Bokingo’s and his co-claimants’ application for titling of the subject land was rejected. On the
other hand, in the same order it was declared that the respondents, if qualified, may file an appropriate
public land application covering the same land. It was further alleged that the said order became final and
executory, and in connection therewith, the respondents were authorized by the City Environment and
Natural Resources Officer of Butuan City to conduct a survey on the subject land. However, petitioner
Bokingo, through his representatives, unjustly prevented the conduct of the said survey. Even when the
matter regarding the survey was submitted to the Lupong Tagapamayapa, petitioner Bokingo still allegedly
refused to allow the respondents to survey the subject land. Hence, the Complaint for Injunction filed by the
respondents where the principal relief sought is to enjoin permanently the illegal acts of the defendants
therein, including petitioner Bokingo, of preventing the survey of the land subject matter of the case.
 In this connection, the Court had the occasion to explain that in determining whether an action is one the
subject matter of which is not capable of pecuniary estimation, the nature of the principal action, or remedy
sought must first be ascertained. If it is primarily for the recovery of a sum of money, the claim is considered
capable of pecuniary estimation, and jurisdiction over the action will depend on the amount of the claim.
However, where the basic issue is something other than the right to recover a sum of money, where the
money claim is purely incidental to, or a consequence of, the principal relief sought, the action is one where
the subject of litigation may not be estimated in terms of money, which is cognizable exclusively by Regional
Trial Courts.
 Significantly, the respondents’ complaint has not sought to recover the possession or ownership of the
subject land. Rather, it is principally an action to enjoin petitioner Bokingo and his representatives from
committing acts that would tend to prevent the survey of the subject land. It cannot be said therefore that it
is one of a possessory action. As such, the subject matter of litigation is incapable of pecuniary estimation
and properly cognizable exclusively by the RTC.

5. Padlan v. Dinglasan G.R. NO. 180321: March 20, 2013 – In all civil actions which involve the title to, or possession
of, real property, or any interest therein, where the assessed value of the property involved exceeds…
FACTS:
 Respondent Elenita Dinglasan was the registered owner of a parcel of land designated as Lot No. 625 which
is covered by a transfer certificate title. While on board a jeepney, Elenita’s mother, Lilia Baluyot, had a
conversation with one Maura Passion regarding the sale of the said property. Believing that Maura was a
real estate agent, Lilia borrowed the owner’s copy of the TCT from Elenita and gave it to Maura. Maura then
subdivided the property into several lots under the name of Elenita and her husband Felicisimo Dinglasan.
 Through a falsified deed of sale bearing the forged signature of Elenita and her husband Felicisimo, Maura
was able to sell the lots to different buyers. Maura sold Lot No. 625-K to one Lorna Ong who later caused the
issuance of TCT No. 134932 for the subject property under her name. A few months later, Lorna sold the lot
to petitioner Editha Padlan for ₱4,000.00. Thus, TCT No. 134932 was cancelled and TCT No. 137466 was
issued in the name of petitioner.
  After learning what had happened, respondents demanded petitioner to surrender possession of Lot No.
625-K, but the latter refused.
 Respondents were then forced to file a case before the Regional Trial Court of Balanga, Bataan for the
Cancellation of Transfer Certificate of Title No. 137466 that was issued in the name of the petitioner.
 The RTC rendered a Decision finding petitioner to be a buyer in good faith and, consequently, dismissed the
complaint.
 The Court of Appeals reversed and set aside the Decision of the RTC and ordered the cancellation of the TCT
issued in the name of Lorna and the petitioner, and the revival of respondents’ own title. The CA found that
petitioner purchased the property in bad faith from Lorna. The CA opined that although a purchaser is not
expected to go beyond the title, based on the circumstances surrounding the sale, petitioner should have
conducted further inquiry before buying the disputed property. The fact that Lorna bought a 5,000-square-
meter property for only ₱4,000.00 and selling it after four months for the same amount should have put
petitioner on guard.
ISSUE:
 Whether or not the RTC has jurisdiction over subject matter of the case?
RULING:
 No, the RTC has no jurisdiction over the subject matter of the case.
 Jurisdiction over the subject matter of a case is conferred by law and determined by the allegations in the
complaint which comprise a concise statement of the ultimate facts constituting the plaintiff's cause of
action. 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 averments in the complaint and the
character of the relief sought are the ones to be consulted. Once vested by the allegations in the complaint,
jurisdiction also remains vested irrespective of whether or not the plaintiff is entitled to recover upon all or
some of the claims asserted therein.
 What determines the jurisdiction of the court is the nature of the action pleaded as appearing from the
allegations in the complaint. The averments therein and the character of the relief sought are the ones to be
consulted.
 From the Complaint, the case filed by respondent is not simply a case for the cancellation of a particular
certificate of title and the revival of another. The determination of such issue merely follows after a court of
competent jurisdiction shall have first resolved the matter of who between the conflicting parties is the
lawful owner of the subject property and ultimately entitled to its possession and enjoyment. The action is,
therefore, about ascertaining which of these parties is the lawful owner of the subject lot, jurisdiction over
which is determined by the assessed value of such lot.
 The Court has held that a complaint must allege the assessed value of the real property subject of the
complaint or the interest thereon to determine which court has jurisdiction over the action. In the case at
bar, the only basis of valuation of the subject property is the value alleged in the complaint that the lot was
sold by Lorna to petitioner in the amount of ₱4,000.00. No tax declaration was even presented that would
show the valuation of the subject property.
 Since the amount alleged in the Complaint by respondents for the disputed lot is only ₱4,000.00, the MTC
and not the RTC has jurisdiction over the action. Therefore, all proceedings in the RTC are null and void.

6. Heirs of Bautista v. Lindo G.R. No. 208232, March 10, 2014 – possessory action, action capable of pecuniary
interest
FACTS:
 Alfredo R. Bautista, petitioner’s predecessor, inherited a free-patent land and covered by an Original
Certificate of Title. A few years later, he subdivided the property and sold it to several vendees, herein
respondents, via a notarized deed of absolute sale. Two months later, the OCT was canceled and Transfer
Certificates of Title (TCTs) were issued in favor of the vendees.
 Three years after the sale, Bautista filed a complaint for repurchase against respondents before the RTC,
Branch 32, Lupon, Davao Oriental anchoring his cause of action on Section 119 of the Public Land Act where
the conveyance of land acquired under the free patent or homestead provisions, when proper, shall be
 subject to repurchase by the applicant, his widow, or legal heirs, within a period of five years from the date
of the conveyance.
 Respondents, in their Answer, raised lack of cause of action, estoppel, prescription, and laches, as defenses.
 Meanwhile, during the pendency of the case, Bautista died and was substituted by petitioner Epifania G.
Bautista.
 Respondents Francisco and Welhilmina Lindo later entered into a compromise agreement with petitioners,
whereby they agreed to cede to Epifania a 3,230 sq.m portion of the property as well as to waive, abandon,
surrender, and withdraw all claims and counterclaims against each other. The compromise was approved by
the RTC in its Decision.
 However, the other respondents filed a Motion to Dismiss alleging that the complaint failed to state the
value of the property sought to be recovered. Moreover, they asserted that the total selling price of all the
properties is only PhP 16,500, and the selling price or market value of a property is always higher than its
assessed value. Since Batas Pambansa Blg. 129, as amended, grants jurisdiction to the RTCs over civil actions
involving title to or possession of real property or interest therein where the assessed value is more than
PhP 20,000, then the RTC has no jurisdiction over the complaint in question since the property which
Bautista seeks to repurchase is below the PhP 20,000 jurisdictional ceiling.
 The RTC issued the assailed order dismissing the complaint for lack of jurisdiction. The trial court found that
Bautista failed to allege in his complaint that the value of the subject property exceeds 20 thousand pesos.
Furthermore, what was only stated therein was that the total and full refund of the purchase price of the
property is PhP 16,500. This omission was considered by the RTC as fatal to the case considering that in real
actions, jurisdictional amount is determinative of whether it is the municipal trial court or the RTC that has
jurisdiction over the case.
ISSUE:
 Whether or not the RTC has jurisdiction over the subject matter of the case?
RULING:
 Yes, the RTC has jurisdiction over the subject matter of the case.
 The Court ruled that the complaint to redeem a land subject of a free patent is a civil action incapable of
pecuniary estimation.
 The course of action embodied in the complaint by the present petitioners’ predecessor, Alfredo R. Bautista,
is to enforce his right to repurchase the lots he formerly owned pursuant to the right of a free-patent holder
under Sec. 119 of the Public Land Act.
 Jurisdiction of the court is determined by the allegations in the complaint and the character of the relief
sought. In determining whether an action is one the subject matter of which is not capable of pecuniary
estimation, the Court has adopted the criterion of first ascertaining the nature of the principal action or
remedy sought. If it is primarily for the recovery of a sum of money, the claim is considered capable of
pecuniary estimation, and whether jurisdiction is in the municipal courts or in the RTCs would depend on the
amount of the claim. But where the basic issue is something other than the right to recover a sum of money,
where the money claim is purely incidental to, or a consequence of, the principal relief sought, the Court has
considered such actions as cases where the subject of the litigation may not be estimated in terms of money,
and, hence, are incapable of pecuniary estimation. These cases are cognizable exclusively by RTCs.
 Settled jurisprudence considers some civil actions as incapable of pecuniary estimation, viz:
1. Actions for specific performance;
2. Actions for support which will require the determination of the civil status;
3. The right to support of the plaintiff;
4. Those for the annulment of decisions of lower courts;
5. Those for the rescission or reformation of contracts;
6. Interpretation of a contractual stipulation.
The Court finds that the instant cause of action to redeem the land is one for specific performance.
 The reconveyance of the title to petitioners is solely dependent on the exercise of such right to repurchase
the lots in question and is not the principal or main relief or remedy sought. Thus, the action of petitioners is,
in reality, incapable of pecuniary estimation, and the reconveyance of the lot is merely the outcome of the
performance of the obligation to return the property conformably to the express provision of the Public
Land Act.