CASE DIGEST : Barangay Piapi v. Talip

 G.R. No. 138248 September 7, 2005

BARANGAY PIAPI, herein represented by its chairman ANDRES L. LUGNASIN and LIBERATO LARGO, RITA LARGO, SABAS MONTECALBO, SR., CARLOS ZAMORA, DONATA SESICAN, DIZAR CASTILLO, ALEJANDOR GICALE, SALVACION SALE, PABLO MORASTIL, JOSE JAVELOSA, ISIDRA BERNAL, FELIX EGHOT, CORAZON EGHOT, ROSALINA REMONDE, ROA EGHOT, CEFERINA LAGROSA, MARIO ARANEZ, ALBERTO CAMARILLO, BOBBY DULAOTO, NOEL ZAMORA, MARTINO MORALLAS, DANILO FAILAGA, MARITA BRAGAT, NATIVIDAD LAGRAMON, RAQUEL GEROZAGA, SHIRLY CESAR, PIO ZAMORA, ANDRES LUGNASIN, ELPIDIO SESICAN, CRESENTA BORJA, CARLITO TANEZA, JR., MARCIAL RELLON, JEANILITO SUMALINOG, ALBERTO ZAMORA, and LUISITO LAGROSA, Petitioners,

vs.

IGNACIO TALIP representing the HEIRS OF JUAN JAYAG, Respondent.

FACTS: On August 28, 1998, petitioners filed with the said RTC a complaint for reconveyance and damages with prayer for issuance of a temporary restraining order and/or writ of preliminary injunction against respondent, docketed as Civil Case No. 3715. Instead of filing an answer, respondent moved to dismiss the complaint on the ground that the RTC has no jurisdiction over the case considering that the assessed value of the land is only ₱6,030.00. In their opposition to the motion to dismiss, petitioners alleged that jurisdiction is vested in the RTC considering that the total assessed value of the property is ₱41,890.00, as shown by a Real Property Field Appraisal and Assessment Sheet. On January 12, 1999, the trial court issued an Order dismissing the complaint for lack of jurisdiction. Petitioners then filed a motion for reconsideration but was denied in an Order dated April 20, 1999. Hence, petitioners directly filed with this Court the instant petition for review on certiorari assailing the trial court’s Order dismissing the complaint for lack of jurisdiction.

ISSUE: WON RTC has jurisdiction

HELD: Indeed, basic as a hornbook principle is that the nature of an action, as well as which court or body has jurisdiction over it, is determined based on the allegations contained in the complaint of the plaintiff, irrespective of whether or not the plaintiff is entitled to recover upon all or some of the claims asserted therein. The Rule requires that "the assessed value of the property, or if there is none, the estimated value thereof, shall be alleged by the claimant. It bears reiterating that what determines jurisdiction is the allegations in the complaint and the reliefs prayed for. Petitioners’ complaint is for reconveyance of a parcel of land. Considering that their action involves the title to or interest in real property, they should have alleged therein its assessed value. However, they only specified the market value or estimated value, which is ₱15,000.00. Pursuant to the provision of Section 33 (3) quoted earlier, it is the Municipal Circuit Trial Court of Padada-Kiblawan, Davao del Sur, not the RTC, which has jurisdiction over the case.