Copioso v. Copioso
REITERATIONFacts
1. The Antecedents: Respondents Lauro, Dolores, Rafael, Esteban, and Corazon Copioso filed a complaint for reconveyance of two parcels of coconut land. They alleged that they, along with their deceased brother Antonio Copioso, were co-owners of the property inherited from their parents. They claimed that Antonio, through fraud and machination, transferred the property to himself and spouses Bernabe and Imelda Doria, who subsequently sold it to third parties. The respondents sought reconveyance of the property based on their co-ownership. 2. Procedural History: The respondents filed their complaint with the Regional Trial Court (RTC). Petitioner Lolita Copioso and spouses Bernabe and Imelda Doria moved to dismiss the complaint, arguing that the Municipal Trial Court (MTC) had jurisdiction due to the low assessed value of the property. The RTC denied these motions, asserting its jurisdiction. Petitioner Lolita Copioso then filed a petition for certiorari and prohibition with the Court of Appeals, challenging the RTC's orders. The Court of Appeals dismissed her petition, affirming the RTC's jurisdiction. This petition for review assails the Court of Appeals' decision and resolution. 3. The Petition: Petitioner Lolita Copioso anchors her argument on Section 33, paragraph (3) of B.P. Blg. 129, as amended by Section 3 of RA 7691, contending that the complaint for reconveyance, involving title, possession, and interest in real property with an assessed value below P20,000.00, falls under the exclusive jurisdiction of the MTC. Conversely, private respondents rely on Section 19, paragraph (1) of the same law, asserting that the complaint, which includes causes of action for annulment of sale and other instruments of false conveyance, is incapable of pecuniary estimation and thus falls within the RTC's jurisdiction. Petitioner seeks review of the appellate court's affirmation of the RTC's jurisdiction.
Issue(s)
Whether the Regional Trial Court (RTC) has jurisdiction over a complaint for reconveyance of real property when the assessed value of the property falls within the exclusive jurisdiction of the Municipal Trial Court (MTC), considering claims for annulment of sale, recovery of common properties, and damages. Whether a complaint for reconveyance, which includes claims for annulment of sale, recovery of common properties, and damages, constitutes a joinder of causes of action that are inherently incapable of pecuniary estimation, thereby vesting jurisdiction in the RTC.
Ruling
The petition is DENIED. The Decision of the Court of Appeals affirming the jurisdiction of the RTC is AFFIRMED.
Ratio Decidendi
On the jurisdiction of the RTC over the complaint for reconveyance: The Court reiterated that the law on jurisdiction distinguishes between civil cases capable of pecuniary estimation and those incapable of pecuniary estimation. For cases involving sums of money or title to, possession of, or any interest in real property, jurisdiction is determined by the assessed value of the property or the amount of the claim. If the assessed value does not exceed P20,000.00 (or P50,000.00 in Metro Manila), jurisdiction lies with the MTC; otherwise, it is with the RTC. However, the Court emphasized that the nature of the action, the allegations, and the reliefs prayed for are determinative of jurisdiction. In this case, while the assessed value of the property fell within the MTC's range, the complaint was for "Reconveyance and/or Recovery of Common Properties Illegally Disposed, with Annulment of Sales and other Instruments of False Conveyance, with Damages, and Restraining Order." The private respondents alleged fraud and machination in the transfer and sale of the property, sought the annulment of deeds of absolute sale, and prayed for damages, moral damages, exemplary damages, litigation expenses, and attorney's fees, amounting to approximately P286,500.00. These claims, particularly the annulment of contracts and the claim for damages, are incapable of pecuniary estimation. Therefore, the RTC properly exercised its jurisdiction over the case. On whether the complaint involves issues incapable of pecuniary estimation: The Court held that the present dispute was a case of joinder of causes of action that comprehended more than just the issue of title, possession, or interest in the real property. It included an action to annul contracts, reconveyance, specific performance, and a claim for damages. These elements are inherently incapable of pecuniary estimation. The Court clarified that if the only issue were naked possession or bare ownership, and the assessed value was low, the MTC might have jurisdiction. However, because the issue of title, ownership, and/or possession was intertwined with the issue of annulment of sale and reconveyance, the case fell within the ambit of the RTC's jurisdiction. The assessed value of the parcels of land became merely an incidental matter, not determinative of the court's jurisdiction.
Main Doctrine
A complaint for reconveyance involving joinder of causes of action, including annulment of sale and claims for damages, is within the jurisdiction of the Regional Trial Court, even if the assessed value of the property involved falls within the Municipal Trial Court's range, as the issues incapable of pecuniary estimation are determinative of jurisdiction.