Montero v. Montero
REITERATIONFacts
The Antecedents: The underlying dispute concerns a parcel of land in Pilar, Abra, originally possessed by Dominga Taeza. Dominga, who died intestate in 1975, left the property, which was issued a Free Patent in her name in 1939. Her possession was allegedly transferred by operation of law to her successors-in-interest. In 1993, petitioner Elmer Montero discovered that the property had been transferred to respondent Santiago Montero, Jr. via an Affidavit of Adjudication dated June 13, 1989. This transfer was allegedly based on Santiago Montero, Jr.'s misrepresentation that he was the sole heir of Jose Montero, Dominga's husband from a previous marriage, despite not being blood-related to Dominga. Consequently, Tax Declaration No. 417 in Dominga's name was cancelled and replaced by Tax Declaration No. 5289 in Santiago Montero, Jr.'s name, and Original Certificate of Title (OCT) No. P-14452 was issued in his name. The dispute escalated when respondents Santiago and Charlie Montero allegedly threatened other heirs and began occupying portions of the land, refusing to reconvey it. Procedural History: Petitioner Elmer Montero filed a Complaint before the Regional Trial Court (RTC) of Bangued, Branch 2, seeking the nullity of the Affidavit of Adjudication, cancellation of the Tax Declaration and OCT, reconveyance of the property, and damages. Respondents Santiago and Charlie Montero moved to dismiss the case, arguing that the RTC lacked jurisdiction due to the property's assessed value of P3,010.00, which they contended placed it under the exclusive original jurisdiction of the Municipal Trial Court. They also argued that the action constituted a collateral attack on the Torrens title. Petitioner Elmer opposed the motion, asserting that the action was incapable of pecuniary estimation and that the attack on the title was direct. The RTC denied the motion to dismiss, finding the cause of action to be a direct attack on the title and incapable of pecuniary estimation. The respondents' motion for reconsideration was also denied. Consequently, the respondents filed a Petition for Certiorari under Rule 65 of the Rules of Court with the Court of Appeals (CA), alleging grave abuse of discretion by the RTC. The Petition: The Court of Appeals granted the respondents' Petition for Certiorari, setting aside the RTC's orders and granting the motion to dismiss. The CA ruled that the case involved title to and possession of real property, and its jurisdiction was determined by the assessed value, which was below the threshold for the RTC. Petitioner Elmer Montero then filed the instant Petition for Review on Certiorari under Rule 45 of the Rules of Court, assailing the CA's decision and resolution. The core issue presented to the Supreme Court is whether the subject matter of petitioner Elmer's Complaint involves title to, possession of, or interest in real property, or if it is incapable of pecuniary estimation. Petitioner Elmer argued that the main objective was the cancellation of the respondents' title, making the action incapable of pecuniary estimation, while the respondents maintained that the action fundamentally concerned ownership and possession of real property, thus falling under the jurisdiction of lower courts based on the assessed value.
Issue(s)
Whether the subject matter of petitioner Elmer's Complaint involves the title to, possession of, or interest in real property, or is incapable of pecuniary estimation; and whether the Regional Trial Court committed grave abuse of discretion in denying the respondents' Motion to Dismiss.
Ruling
The petition is denied. The assailed Decision and Resolution of the Court of Appeals are affirmed. The Regional Trial Court had no jurisdiction to hear the case.
Ratio Decidendi
On the issue of jurisdiction over the subject matter and grave abuse of discretion: The Court held that the nature of an action is determined by the allegations in the complaint and the principal relief sought. Petitioner Elmer's Complaint unequivocally states that he seeks to compel respondents to respect the right of ownership and possession over the subject property by the heirs of Dominga Taeza. The Complaint explicitly states that petitioner was establishing his "rightful ownership" over the subject property. Furthermore, the Complaint prays for the reconveyance of the property and the demolition of structures, which are actions for reconveyance and recovery of possession. Jurisprudence consistently holds that actions for reconveyance, cancellation of title, or quieting of title over real property fall under cases involving "title to, or possession of, real property, or any interest therein." The Court clarified that the cancellation of the respondents' title (OCT No. P-14452) would merely be a necessary consequence of establishing that the respondents lack title to the real property, and not the primary relief sought. Therefore, the subject matter of the Complaint involves title to, possession of, and interest in real property. Since the assessed value of the property is P3,010.00, which is below P20,000.00, exclusive original jurisdiction lies with the Metropolitan Trial Courts, Municipal Trial Courts, or Municipal Circuit Trial Courts, not the RTC. The CA correctly found that the RTC lacked jurisdiction.
Main Doctrine
The jurisdiction of a court over the subject matter of an action is determined by the allegations in the complaint and the principal relief sought, in light of the law that apportions the jurisdiction of courts. An action involving title to, or possession of, real property, where the assessed value is P20,000.00 or less, falls under the exclusive original jurisdiction of the Metropolitan, Municipal, or Municipal Circuit Trial Courts, not the Regional Trial Court.