Bautista v. Lindo
REITERATIONFacts
The Antecedents: Alfredo R. Bautista inherited a parcel of land in 1983, which he later subdivided and sold to various vendees, including the respondents, through a notarized deed of absolute sale dated May 30, 1991. Subsequently, the original certificate of title was canceled, and new transfer certificates of title were issued in favor of the buyers. Three years after the sale, Bautista initiated a complaint for repurchase against the respondents, asserting his right under Section 119 of Commonwealth Act No. 141, the Public Land Act, which provides a five-year period from the date of conveyance for the repurchase of land acquired under free patent or homestead provisions. Procedural History: Following Bautista's death during the pendency of the case, he was substituted by his surviving heirs. A compromise agreement was reached with some respondents, Francisco and Welhilmina Lindo, which was approved by the Regional Trial Court (RTC). However, other respondents filed a Motion to Dismiss, arguing that the RTC lacked jurisdiction because the complaint failed to state the value of the property sought to be recovered, and the total selling price was below the P20,000 jurisdictional threshold for RTCs in real actions. The RTC granted this motion, dismissing the complaint for lack of jurisdiction. The petitioners' motion for reconsideration was subsequently denied. The Petition: The petitioners seek review of the RTC's dismissal orders, arguing that the motion to dismiss was belatedly filed and that the respondents are estopped from questioning jurisdiction due to their extensive participation in the proceedings for nine years. They contend that an action for repurchase under Section 119 of CA 141 is not a real action but one incapable of pecuniary estimation, thus falling within the RTC's exclusive original jurisdiction. The petition is filed under Rule 45 of the Rules of Court, assailing the RTC's April 25, 2013 Order and its July 3, 2013 Order denying reconsideration.
Issue(s)
Whether the RTC erred in admitting the belatedly filed Motion to Dismiss. Whether the action for repurchase is a real action, and whether the RTC erred in dismissing the case for lack of jurisdiction.
Ruling
The petition is meritorious. The Supreme Court reversed and set aside the assailed Orders of the RTC and ordered the RTC to proceed with the resolution of the case. The Supreme Court held that the RTC erred in dismissing the case for lack of jurisdiction.
Ratio Decidendi
No specific ratio provided in the text for the issue of admitting the belatedly filed Motion to Dismiss. Therefore, no ratio can be provided for this issue. On the issue of jurisdiction and the nature of the action: The Supreme Court held that the action to redeem land subject to a free patent under Section 119 of Commonwealth Act No. 141 is a civil action incapable of pecuniary estimation because the primary relief sought is the enforcement of a legal right to repurchase, akin to specific performance. Jurisdiction is determined by the complaint's allegations and the relief sought. While the action involves real property, the repurchase right is principal, and reconveyance is incidental. Therefore, the RTC has exclusive original jurisdiction, irrespective of the property's value. Even if treated as a real action, the respondents' active participation for nine years estopped them from questioning the RTC's jurisdiction, citing Heirs of Jose Fernando v. De Belen. The RTC's dismissal for lack of jurisdiction was erroneous, as the court had jurisdiction, and the parties were estopped from assailing it.
Main Doctrine
An action to redeem land subject to a free patent under Section 119 of Commonwealth Act No. 141 is an action for specific performance, which is incapable of pecuniary estimation, and thus falls under the exclusive original jurisdiction of the Regional Trial Court, regardless of the assessed value of the property. Furthermore, parties who actively participate in the proceedings before a court are estopped from questioning its jurisdiction.