First Sarmiento Property Holdings, Inc vs Philippine Bank Communica ons

Facts:

First Sarmiento obtained from Philippine Bank of Communica ons (PBCOM) a P40,000,000.00 loan, which
was secured by a real estate mortgage.

PBCOM sent First Sarmiento several demand le ers, yet First Sarmiento s ll failed to pay the principal
amount and accrued interest on the loan. This prompted PBCOM to resort to extrajudicial foreclosure of
the mortgaged proper es, a recourse granted to it under the loan agreement.

First Sarmiento filed a Complaint for annulment of real estate mortgage and its amendments.

Issue:

Whether the ac on was incapable of pecuniary es ma on.

Held:

Yes. When the basic issue is something other than the right to recover a sum of money, or where the
money claim is purely incidental to, or a consequence of, the principal relief sought like in suits of specific
performance where the subject of the li ga on may not be es mated in terms of money.

To determine the nature of an ac on, whether or not its subject ma er is capable or incapable of
pecuniary es ma on, the nature of the principal ac on or relief sought must be ascertained. If the
principal relief is for the recovery of a sum of money or real property, then the ac on is capable of
pecuniary es ma on. However, if the principal relief sought is not for the recovery of sum of money or
real property, even if a claim over a sum of money or real property results as a consequence of the principal
relief, the ac on is incapable of pecuniary es ma on.

The Regional Trial Court has jurisdic on.

Surviving Heirs of Alfredo R. Bau sta vs Francisco Lindo

Facts:

Alfredo Bau sta seeks to repurchase several free-patent land he sold to Respondents before the RTC
Lupon, Davao Oriental.

Respondents filed a Mo on to Dismiss asser ng that the total selling price of all the proper es is only
sixteen thousand five hundred pesos (PhP 16,500).

Issue:

Whether the dismissal of the case on the ground of lack of jurisdic on over the subject ma er was proper.

Held:

No. The instant cause of ac on to redeem the land is one for specific performance.

The reconveyance of the tle to pe oners is solely dependent on the exercise of such right to repurchase
the lots in ques on and is not the principal or main relief or remedy sought. Thus, the ac on of pe oners
is, in reality, incapable of pecuniary es ma on, and the reconveyance of the lot is merely the outcome of
the performance of the obliga on to return the property conformably to the express provision of CA 141.

Moreover, the Respondents having fully par cipated in all stages of the case, and even invoking the RTC's
authority by asking for affirma ve reliefs, respondents can no longer assail the jurisdic on of the said trial
court. Simply put, considering the extent of their par cipa on in the case, they are, as they should be,
considered estopped from raising lack of jurisdic on as a ground for the dismissal of the ac on.

Se led jurisprudence considers some civil ac ons as incapable of pecuniary es ma on, viz:

1. Ac ons for specific performance;

2. Ac ons for support which will require the determina on of the civil status;
3. The right to support of the plain ff;
4. Those for the annulment of decisions of lower courts;
5. Those for the rescission or reforma on of contracts;
6. Interpreta on of a contractual s pula on.

Heirs of Generoso Sebe

Facts:

Spouses Sebe filed a case of Annulment of Document, Reconveyance and Recovery of Possession of two
lots, which had a total assessed value of P9,910.00, plus damages against defendants Veronico Sevilla and
Technology and Livelihood Resources Center before the MTC.

Issue:

Whether the jurisdic on is with the RTC.

Held:

No. The total assessed value of the two lots subject of the suit is P9,910.00. Clearly, this amount does not
exceed the jurisdic onal threshold value of P20,000.00 fixed by law.

The present ac on is not about the declara on of the nullity of the documents or the reconveyance to the
Sebes of the cer ficates of tle covering the two lots. These would merely follow a er the trial court shall
have first resolved the issue of which between the contending par es is the lawful owner of such lots, the
one also en tled to their possession.

Barangay Piapi vs Ignacio Talip represen ng heirs of Juan Jayag

Facts:

Pe oners filed with the said RTC a complaint for reconveyance and damages with prayer for issuance of
a temporary restraining order and/or writ of preliminary injunc on against respondent.

Instead of filing an answer, respondent moved to dismiss the complaint on the ground that the RTC has no
jurisdic on over the case considering that the assessed value of the land is only P6,030.00.

Issue:

Whether RTC has jurisdic on.

Held:

No. The Rule requires that "the assessed value of the property, or if there is none, the es mated value
thereof, shall be alleged by the claimant.

Where the ul mate objec ve of the plain ffs, like pe oners herein, is to obtain tle to real property, it
should be filed in the proper court having jurisdic on over the assessed value of the property subject
thereof."

Indeed, basic as a hornbook principle is that the nature of an ac on, as well as which court or body has
jurisdic on over it, is determined based on the allega ons contained in the complaint of the plain ff,
irrespec ve of whether or not the plain ff is en tled to recover upon all or some of the claims asserted
therein