CASE DIGEST : CAPIOSO VS CAPIOSO

[G.R. No. 149243. October 28, 2002.]

LOLITA B. COPIOSO, Petitioner, v. LAURO, DOLORES, RAFAEL, ESTEBAN, and CORAZON, all surnamed COPIOSO, and COURT OF APPEALS, Respondents

FACTS : On 4 July 2000 respondents Lauro, Dolores, Rafael, Esteban and Corazon, all surnamed Copioso, filed a complaint2 for reconveyance of two (2) parcels of coconut land situated in Banilad, Nagcarlan, Laguna, against Lolita B. Copioso, spouses Bernabe and Imelda Doria, and the estate of deceased Antonio Copioso, as well as vendees Dolores Reduca, Mercedes Reduca, Rosario Pascua, Elvira Bombasi and Federico Casabar. Respondents alleged that they together with their deceased brother Antonio Copioso were co-owners of the subject property having inherited the same from their parents, and that through fraud and machination Antonio had the property transferred to his name and that of spouses Bernabe and Imelda Doria who subsequently sold the same to third parties. When respondents claimed in a manifestation with motion for bill of particulars that the assessed value of the subject property was P3,770.00, petitioner Lolita Copioso and spouses Bernabe and Imelda Doria separately moved to dismiss the complaint on the ground that it was the Municipal Trial Court (MTC) and not the Regional Trial Court (RTC) that had jurisdiction over the case considering that the assessed value of the property was lower than P20,000.00. The trial court in its twin orders of 5 and 12 September 2000 denied the motions to dismiss holding that since the subject matter of the action was beyond pecuniary estimation it was properly within its jurisdiction.3 Lolita Copioso's Motion for Reconsideration was denied,4 hence, she filed with the Court of Appeals a petition for certiorari and prohibition praying for the annulment of the twin orders of the trial court. The appellate court denied the petition thus affirming the jurisdiction of the RTC over the complaint for reconveyance. Motion for reconsideration thereon was similarly denied by the appellate court, hence this petition.

ISSUE :

HELD : The law on jurisdiction of trial courts over civil cases is neither ambiguous nor confusing. Sec. 33, par. (3), in relation to Sec. 19 par. (2) of B.P. 129 as amended by RA 7691, deals with civil cases capable of pecuniary estimation. On the other hand, Sec. 33, par. (3), in relation to Sec. 19, par. (1), applies to cases incapable of pecuniary estimation

Sec. 33, par. (3), in relation to Sec. 19, par. (2), of B.P. 129, as amended by RA 7691, provides that in civil cases involving sum of money or title to, possession of, or any interest in real property, jurisdiction is determined on the basis of the amount of the claim or the assessed value of the real property involved, such that where the sum of money or the assessed value of the real property does not exceed P20,000.00, or P50,000.00 in Metro Manila, jurisdiction lies with the MTC; and where it exceeds that amount, jurisdiction is vested with the RTC

Indeed, the present dispute 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 jurisdictional range of the MTC. Nonetheless, the nature of the action filed, the allegations set forth, and the reliefs prayed for, forestall its cognizance by the MTC

Clearly, this is a case of joinder of causes of action which comprehends more than the issue of title to, possession of, or any interest in the real property under contention but includes an action to annul contracts, reconveyance or specific performance, and a claim for damages, which are incapable of pecuniary estimation and thus properly within the jurisdiction of the RTC.

As correctly opined by the appellate court, if the only issue involved herein is naked possession or bare ownership, then petitioner Lolita Copioso would not be amiss in her assertion that the instant complaint for reconveyance, considering the assessed value of the disputed property, falls within the exclusive jurisdiction of the MTC. But as herein before stated, the issue of title, ownership and/or possession thereof is intertwined with the issue of annulment of sale and reconveyance hence within the ambit of the jurisdiction of the RTC. The assessed value of the parcels of land thus becomes merely an incidental matter to be dealt with by the court, when necessary, in the resolution of the case but is not determinative of its jurisdiction.