Spouses Huguete v. Spouses Embudo
REITERATIONFacts
The Antecedents: Petitioners spouses Jorge and Yolanda Huguete filed a complaint against respondent spouses Teofredo Amarillo Embudo and Marites Huguete-Embudo for annulment of a Transfer Certificate of Title (TCT) No. 99694, Tax Declaration No. 46493, and a Deed of Sale, praying for partition and damages. Petitioners alleged that Teofredo sold to them a 50-square meter portion of his 150-square meter lot for P15,000.00. Teofredo had acquired the lot from Ma. Lourdes Villaber-Padillo, with TCT No. 99694 issued solely in his name. Despite demands, Teofredo refused to partition the lot. Procedural History: Respondents filed a Motion to Dismiss, arguing that the total assessed value of the land was P15,000.00, which falls within the exclusive jurisdiction of the Municipal Trial Court (MTC) pursuant to Batas Pambansa Blg. 129 (BP 129), as amended by Republic Act No. 7691. Petitioners opposed, asserting that the subject matter was incapable of pecuniary estimation, thus cognizable by the Regional Trial Court (RTC) under BP 129. The RTC dismissed the complaint for lack of jurisdiction, and a subsequent Motion for Reconsideration was denied. The Petition: Petitioners sought review, arguing that the RTC erred in holding it had no jurisdiction, disregarding provisions on actions incapable of pecuniary estimation and settled jurisprudence. They also argued that respondents, by invoking the court's authority in their counterclaim, were estopped from denying jurisdiction.
Issue(s)
Whether the Regional Trial Court erred in holding that it has no jurisdiction over the case. Whether respondents are estopped from denying the jurisdiction of the Regional Trial Court.
Ruling
The petition lacks merit. The Supreme Court affirmed the Orders of the Regional Trial Court dismissing the complaint for lack of jurisdiction. The dispositive portion states: "WHEREFORE, in view of the foregoing, the instant petition for review is DENIED. The Order dated June 27, 2001 of the Regional Trial Court of Cebu City, Branch 7, dismissing Civil Case No. CEB-24925, and its Order dated July 26, 2001 denying petitioners’ Motion for Reconsideration, are AFFIRMED."
Ratio Decidendi
On the issue of jurisdiction: The Supreme Court reiterated that the nature of an action and the court's jurisdiction are determined by the allegations in the complaint and the relief sought. In this case, the principal purpose of the petitioners was to secure title to the 50-square meter portion of the property they purchased. Their cause of action was based on their right as purchasers, and they prayed to be declared owners of the sold property. Therefore, the complaint involved title to real property or any interest therein. The alleged value of the land purchased was P15,000.00, which falls within the jurisdiction of the Municipal Trial Court, as provided by Section 33(3) of BP 129, as amended by RA 7691. The annulment of the deed of sale and the TCT were prayed for as necessary steps before the lot could be partitioned and conveyed to the petitioners. The Court clarified that the reliance on Russell v. Vestil was misplaced because, unlike that case where the primary issue was heirship and recognition, the present action's ultimate objective was to obtain title to real property, making it an action capable of pecuniary estimation, with jurisdiction dependent on the assessed value. The Court emphasized that the nature of an action is determined by the allegations and reliefs prayed for, not merely by the caption of the complaint. The ultimate objective here was to obtain title to real property, which should be filed in the court having jurisdiction over the assessed value of the property. On the issue of estoppel: The Court did not explicitly rule on the issue of estoppel in the provided text, but the dismissal of the petition implies that this argument was not given weight, likely because the primary issue of jurisdiction was resolved against the petitioners.
Main Doctrine
The nature of an action and the jurisdiction of the court are determined by the allegations in the complaint and the character of the relief sought. An action for annulment of a deed of sale and partition, where the ultimate objective is to obtain title to real property, is an action capable of pecuniary estimation, and jurisdiction is determined by the assessed value of the property.