Russell v. Vestil
REITERATIONFacts
1. The Antecedents: The underlying dispute concerns a parcel of land, Lot 6149 in Liloan, Cebu, inherited by the legal heirs of the deceased spouses Casimero Tautho and Cesaria Tautho. The petitioners allege that the private respondents, who are also heirs, executed a document titled "DECLARATION OF HEIRS AND DEED OF CONFIRMATION OF A PREVIOUS ORAL AGREEMENT OF PARTITION" on June 6, 1990. Petitioners claim this document is false and perjurious, as it divides the property among the private respondents to the exclusion of the petitioners, who are also entitled heirs. The petitioners assert that no such oral partition occurred and that they were unjustly excluded from their rightful share of the inheritance. 2. Procedural History: Petitioners initiated this case by filing a complaint on September 28, 1994, with the Regional Trial Court (RTC) of Mandaue City, Branch 56, seeking a declaration of nullity of the deed and partition of the land. The private respondents filed a Motion to Dismiss, arguing that the RTC lacked jurisdiction because the assessed value of the land was P5,000.00, placing it within the exclusive jurisdiction of the Municipal Circuit Court of Liloan, Compostela, as per Batas Pambansa Blg. 129, as amended by R.A. No. 7691. The petitioners opposed this, contending that their action was one incapable of pecuniary estimation, thus falling under the RTC's jurisdiction. On January 12, 1995, the respondent judge granted the motion and dismissed the complaint. A subsequent Motion for Reconsideration filed by the petitioners was denied by the respondent judge on February 13, 1995. 3. The Petition: The petitioners filed a Petition for Certiorari with the Supreme Court, seeking to set aside the RTC's orders of dismissal and denial of reconsideration. The sole issue presented to the Supreme Court is whether the RTC has jurisdiction over Civil Case No. MAN-2275. Petitioners argue that their primary action is for the annulment of the deed, which is an action incapable of pecuniary estimation and therefore falls within the exclusive original jurisdiction of the RTC, as provided by Section 19(1) of B.P. 129. They contend that the prayer for partition is merely incidental to the main action for annulment. The private respondents, conversely, maintain that the action is for re-partition and, given the assessed value, should be handled by the Municipal Circuit Court.
Issue(s)
Whether the Regional Trial Court has jurisdiction to entertain Civil Case No. MAN-2275; specifically, whether the action for declaration of nullity of a document and partition is an action incapable of pecuniary estimation. Whether the subject matter of the complaint is the annulment of a document, making it an action incapable of pecuniary estimation, irrespective of the assessed value of the real property involved.
Ruling
The petition is granted. The Order dismissing Civil Case No. MAN-2275, as well as the Order denying the motion for reconsideration, is set aside. The Regional Trial Court, Branch 56, Mandaue City is ordered to proceed with dispatch in resolving Civil Case No. MAN-2275.
Ratio Decidendi
On the issue of jurisdiction and the nature of the action: The Supreme Court held that the Regional Trial Court has jurisdiction over the case because the main purpose of the petitioners' complaint was to declare null and void the "DECLARATION OF HEIRS AND DEED OF CONFIRMATION OF PREVIOUS ORAL PARTITION," with the prayer for partition being merely incidental. The Court reiterated that if the basic issue is something other than the right to recover money, and any money claim is merely incidental, the action is not capable of pecuniary estimation and falls within the exclusive jurisdiction of the RTC. On the nature of the action and jurisdiction: The Court clarified that the subject matter of the complaint was the annulment of a document, specifically the deed where private respondents declared themselves as the sole heirs and divided the property. This act of annulling a document is fundamentally an action incapable of pecuniary estimation. The Court emphasized that jurisdiction is conferred by law and determined by the allegations in the complaint and the character of the relief sought, irrespective of the plaintiff's entitlement to the claims; therefore, actions concerning real property with a specific assessed value are not relevant when the primary action is the annulment of a document.
Main Doctrine
An action to annul a document, even if it involves property, is an action incapable of pecuniary estimation and falls within the exclusive original jurisdiction of the Regional Trial Court, as the prayer for partition is merely incidental to the primary relief sought.