Remedial Law

GENESIS INVESTMENT v. HEIRS OF CEFERINO EBARASABA GR No. 181622, Nov. 20, 2013 B.P. Blg. 129, Actions Incapable of Pecuniary Estimation, RTC-Jurisdiction

FACTS:

Respondents filed a Complaint for “Declaration of Nullity of Documents, Recovery of Shares, Partition, Damages and Attorney’s Fees” against herein petitioners.  

Petitioners filed a Motion to Dismiss contending, among others, that the RTC has no jurisdiction to try the case on the ground that, as the case involves title to or possession of real property or any interest therein and since the assessed value of the subject property does not exceed P20,000.00 (the same being only P11,990.00), the action falls within the jurisdiction of the MTC.

The RTC granted petitioners’ Motion to Dismiss.

Respondents filed a Motion for Partial Reconsideration, arguing that their complaint consists of several causes of action, including one for annulment of documents, which is incapable of pecuniary estimation and, as such, falls within the jurisdiction of the RTC.

The RTC issued an Order granting respondents’ Motion for Partial Reconsideration and reversing its earlier Order.

After their Motion for Reconsideration was denied, petitioners filed a petition for certiorari with the CA. 

However, the CA dismissed the petition, holding that the subject matter of respondents’ complaint is incapable of pecuniary estimation and, therefore, within the jurisdiction of the RTC, considering that the main purpose in filing the action is to declare null and void the documents assailed therein.

Petitioners’ Motion for Reconsideration was, subsequently, denied by the CA.

Hence, the instant petition for review on certiorari.

ISSUE:

Whether the RTC has jurisdiction over the case where the allegations in the complaint shows that the main cause of action is for the Recovery of their Title, Interest, and Share over a Parcel of Land, which has an assessed value of P11,990.00.

RULING:

The petition lacks merit.

It is true that one of the causes of action of respondents pertains to the title, possession and interest of each of the contending parties over the contested property, the assessed value of which falls within the jurisdiction of the MTC. However, a complete reading of the complaint would readily show that, based on the nature of the suit, the allegations therein, and the reliefs prayed for, the action is within the jurisdiction of the RTC.

It is clear from the records that respondents’ complaint was for “Declaration of Nullity of Documents, Recovery of Shares, Partition, Damages and Attorney’s Fees.” 

In filing their Complaint with the RTC, respondents sought to recover ownership and possession of their shares in the disputed parcel of land by questioning the due execution and validity of the Deed of Extrajudicial Settlement with Sale as well as the Memorandum of Agreement entered into by and between some of their co-heirs and herein petitioners.  

Aside from praying that the RTC render judgment declaring as null and void the said Deed of Extrajudicial Settlement with Sale and Memorandum of Agreement, respondents likewise sought the following: 

(1) nullification of the Tax Declarations subsequently issued in the name of petitioner Cebu Jaya Realty, Inc.; 

(2) partition of the property in litigation; 

(3) reconveyance of their respective shares; and 

(3) payment of moral and exemplary damages, as well as attorney’s fees, plus appearance fees.

Clearly, this is a case of joinder of causes of action which comprehends more than the issue of partition of or recovery of shares or interest over the real property in question but includes an action for declaration of nullity of contracts and documents which is incapable of pecuniary estimation.

Since the principal action sought in respondents’ Complaint is something other than the recovery of a sum of money, the action is incapable of pecuniary estimation and, thus, cognizable by the RTC. 

Well entrenched is the rule that jurisdiction over the subject matter of a case 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.

Moreover, it is provided under Section 5 (c), Rule 2 of the Rules of Court that where the causes of action are between the same parties but pertain to different venues or jurisdictions, the joinder may be allowed in the RTC provided one of the causes of action falls within the jurisdiction of said court and the venue lies therein. 

Thus, as shown above, respondents’ complaint clearly falls within the jurisdiction of the RTC.

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