Genesis Investment v. Ebarasabal
REITERATIONFacts
1. The Antecedents: The underlying dispute concerns a parcel of land originally owned by Roman Ebarsabal. Upon his death, his eight children became co-owners. One of his children, Gil Ebarsabal, had his heirs execute a Deed of Extrajudicial Settlement with Sale, selling the entire property to Genesis Investment, Inc. The respondents, who are heirs of the other seven children of Roman Ebarsabal, were not involved in this transaction and claim they are co-owners of the property. They allege that the sale was conducted without their knowledge or consent, and that the defendants acted in bad faith. 2. Procedural History: The respondents filed a Complaint with the Regional Trial Court (RTC) of Barili, Cebu, seeking the nullity of documents, recovery of shares, partition, and damages. The petitioners filed a Motion to Dismiss, arguing that the RTC lacked jurisdiction because the assessed value of the property was below P20,000.00, thus falling under the Municipal Trial Court's (MTC) jurisdiction. The RTC initially granted the motion but later reconsidered and reversed its decision, asserting jurisdiction because the primary relief sought was the annulment of documents, which is incapable of pecuniary estimation. The petitioners then filed a petition for certiorari with the Court of Appeals (CA), which affirmed the RTC's jurisdiction. The CA denied the petitioners' subsequent motion for reconsideration. 3. The Petition: The petitioners are seeking a review on certiorari under Rule 45 of the Rules of Court, asking the Supreme Court to reverse the CA's decision. They contend that the CA gravely erred in concluding that the RTC has jurisdiction, arguing that the main cause of action is the recovery of title, interest, and share over the land, which has an assessed value within the MTC's jurisdiction. The core of their argument is that the nature of the action, based on the allegations and reliefs sought, should be determined by the assessed value of the property, not by the claim of nullity of documents.
Issue(s)
Whether the Regional Trial Court has jurisdiction over the instant case when the primary cause of action is the recovery of title, interest, and share over a parcel of land with an assessed value of ₱11,990.00, considering the principal relief sought is the declaration of nullity of the Deed of Extrajudicial Settlement with Sale and other related documents. Whether the action for declaration of nullity of documents, recovery of shares, partition, damages, and attorney's fees is an action incapable of pecuniary estimation, and whether the recovery of shares, partition, and damages are merely incidental to or consequences of the principal relief sought.
Ruling
The petition is denied. The Decision and Resolution of the Court of Appeals are affirmed, upholding the jurisdiction of the Regional Trial Court over the case.
Ratio Decidendi
On the issue of jurisdiction: The Court held that while the case involves title to or possession of real property with an assessed value within the MTC's jurisdiction, the primary relief sought by the respondents is the declaration of nullity of the Deed of Extrajudicial Settlement with Sale and other related documents. This action for annulment of documents is considered incapable of pecuniary estimation. Therefore, the case falls within the exclusive original jurisdiction of the Regional Trial Court. The Court reiterated the principle that jurisdiction is conferred by law and is determined by the allegations in the complaint and the character of the relief sought, irrespective of whether the party is entitled to all or some of the claims asserted. The joinder of causes of action, where one cause of action is incapable of pecuniary estimation and falls within the RTC's jurisdiction, is permissible. The Court cited Singson v. Isabela Sawmill, Russell v. Vestil, and Social Security System v. Atlantic Gulf and Pacific Company of Manila Inc. in support of this ruling. On the issue of whether the action is incapable of pecuniary estimation: The Court emphasized that the principal relief sought was the nullification of the Deed of Extrajudicial Settlement with Sale, making the recovery of shares a necessary consequence of such nullification. Thus, the action is not primarily for the recovery of a sum of money but for the annulment of contracts, which is cognizable by the RTC. The recovery of shares, partition, and damages are merely incidental to or consequences of the principal relief sought.
Main Doctrine
An action for declaration of nullity of documents, even if involving title to or possession of real property, is an action incapable of pecuniary estimation and falls within the exclusive original jurisdiction of the Regional Trial Court, provided that the primary relief sought is the annulment of said documents.