2. San Pedro vs.

Asdala

FACTS: The heirs Apolonio and Valeriana Dionisio filed a complaint with the MTC of QC (Branch 42 to)
against Ana De Guia San Pedro, Alejo Dopeño, and Wood Crest Residents Association Inc. for Accion
Reinvidicatoria, Quieting of Title, and Damages. They alleged that the property located in Batasan Hills,
with an assessed value of P32,100.00, was titled in the name of the spouses Dionisio. They also alleged
that the San Pedro prevented them from entering, possessing, and using the property, and that their
Certificate of Title was spurious.

The San Pedro et al filed a Motion to Dismiss on the ground of lack of jurisdiction. They claimed
that the case incapable of pecuniary estimation which is under the jurisdiction of the RTC. The MTC
denied the motion to dismiss. San Pedro filed a petition for certiorari with the RTC citing grave abuse of
discretion amounting to lack or excess of jurisdiction on the part of MTC. The petition was denied. They
filed a petition for certiorari with the CA citing the same but was also denied.

ISSUE: Whether or not MTC has jurisdiction

HELD: Yes. Prior to R.A. No. 7691 amending BP 129, there was no substantial distinction between a
case the subject matter of which is incapable of pecuniary estimation and one involving title to property.
After the amendment, the distinction of the two classes became crucial as it expands the jurisdiction of
the first level courts to include all civil actions involving title to, possession of, real property, or any
interest therein where the assessed value of the property or interest therein does not exceed P20,000
or in civil cases in Metro Manila, P50,000. Under the present law, the subject matter in this case falls
within the P50,000 benchmark for Metro Manila. Therefore, MTC has jurisdiction over the case.

5. Cabrera vs. Clarin

FACTS: Nestor Cabrera made several demands to spouses Clarin, spouses Barrios, spouses Serafin, and
spouses Moreno to vacate the premises of the property he alleged to own. He also alleged that he was
in actual and physical possession of the land until the discovery of the encroachment of respondents. A
complaint for accion publiciana was filed by Cabrera against the respondents.

The respondents filed a Motion to Dismiss on the ground of lack of jurisdiction. They claimed
that Cabrera failed to state the assessed value of the property which would determine the correct
amount of docket fees. The motion was denied and the RTC ruled in favor of Cabrera. On appeal, the CA
reversed the ruling of the RTC. Cabrera filed a petition for review on certiorari.

ISSUE: Whether or not RTC had jurisdiction over the case

HELD: No. A perusal of the complaint shows that Cabrera failed to state the assessed value of the
property. BP 129 provides for the specific amount of the assessed value of the property as determinant
to whether the MTC or the RTC has exclusive original jurisdiction. Accordingly, the jurisdictional element
of the case is the assessed value of the property. On its face, there is no showing that the RTC has
jurisdiction exclusive of the MTC. Absent any allegation of the assessed value, it cannot be readily be
determined which court has original and exclusive jurisdiction. The courts cannot take judicial notice of
the assessed or market value of the land. Therefore, RTC erred in resolving the case.

8. Concha vs. Lumocso

FACTS: The heirs of spouses Dorotea and Valeriano Concha claim to be rightful owners of a two parcels
of land located in Cogon, Dipolog City. The said land was covered by Commonwealth Act No. 141
otherwise known as the Public Land Act. Gregorio Lumocso, Crisita Lumocso Vda. De Daan, and Jacinto
Lumocso are the patent holders and registered owners of the subject lots. Records show that Valeriano
Concha and his children filed a complaint for Reconveyance and/or Annulment of Title with Damages.
The complaint was filed with the RTC.

Respondents moved for the dismissal of the case on the ground of lack of jurisdiction, among
others. They argued that the subject property was less than P20,000, and that the case was under the
jurisdiction of the MTC. The petitioners argued that the complaint was one for reconveyance or
annulment of title the subject of which is incapable of pecuniary estimation.

ISSUE: Whether or not RTC has jurisdiction.

HELD: No. The MTC has exclusive original jurisdiction over the case. The contention of the petitioners
that the subject matter is incapable of pecuniary estimation is incorrect. An action for Reconveyance or
for Annulment of Title falls within civil actions which involve title to, possession of, real property, or any
interest therein. Being in the nature of reconveyance or actions to remove cloud on one’s title, the case
falls within Section 19 (2) of BP 129, and not Section 19 (1). Since the assessed value of the property is
less that P20,000, the same falls within the jurisdiction of the MTC.

11. Russell vs. Vestil

ULALIA RUSSELL, RUPERTO TAUTHO, FRANCISCO TAUTHO, SUSANA T. REALES, APITACIO TAUTHO,
DANILO TAUTHO, JUDITHA PROS, GREGORIO TAUTHO, DEODITA T. JUDILLA, AGRIPINO TAUTHO, FELIX
TAUTHO, WILLIAM TAUTHO, AND MARILYN PERALES, petitioners, vs.

HONORABLE AUGUSTINE A. VESTIL, ADRIANO TAGALOG, MARCELO TAUTHO, JUANITA MENDOZA,

DOMINGO BANTILAN, RAUL BATALUNA AND ARTEMIO CABATINGAN, respondents

FACTS: Casimero Tautho and Cesaria Tautho owned a parcel of land situated in Mandaue City. Upon
their death, the property was inherited by their legal heirs, the petitioners and the private respondents.
The lot remained undivided. The petitioners discovered a public document denominated “Declaration of
Heirs and Deed of Confirmation of a Previous Oral Agreement of Partition”. By virtue of the said deed,
the private respondents divided the property among themselves to the exclusion of petitioners.
Petitioners filed a complaint for declaration of nullity and partition of the public document with the RTC.

The private respondents moved to dismiss the case on the ground of lack of jurisdiction. They
claimed that the assessed value of the property is P5,000 which falls under the jurisdiction of the MTC.

ISSUE: Whether or not RTC has jurisdiction

HELD: Yes. The complaint filed before the RTC is to declare the document null and void. Declaration of
nullity of a public document is a case the subject matter of which is incapable of pecuniary estimation.
Since the subject matter of the case is the public document and not the property, the assessed value of
the property is immaterial in the determination of jurisdiction. Even though the complaint also prayed
for partition of the property, it is only incidental to the main action of declaration of nullity. 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, regardless of other claims that the plaintiff may assert.

14. Salvador vs. Patricia Inc.

FACTS: An action for injunction and quieting of title was filed to determine who owns the property
along Juan Luna St. occupied by plaintiff Salvador et.al., and intervenor Ciriano Mijares. To prevent
Patricia Inc. from evicting the plaintiffs, the latter applied for preliminary injunction pending the action
for quieting of title. A Complaint-in-Intervention was filed by the City of Manila as owner of the land
occupied by the plaintiffs.

The RTC ruled in favor of the plaintiffs, permanently enjoining Patricia Inc. from doing any act
that would evict the plaintiffs and from collecting rentals. The RTC held that the property in question
was owned by the City of Manila, thus Patricia Inc. had no right to evict nor collect rentals from the
plaintiffs.

The CA reversed the ruling of the RTC. It held that the plaintiffs are without necessary interest,
either legal or equitable title, to institute an action for quieting of title.

ISSUE: Whether or not RTC correctly exercised jurisdiction over the action for quieting of title

HELD: No. The cause of action of this case is for the quieting of title, which by nature is a real action. BP
129 provides that jurisdiction over civil actions which involves title to, possession of, real property, or
any interest therein is determined by the assessed value of the property. If the same is less than P50,000
(Metro Manila), the MTC has jurisdiction, otherwise, the RTC has jurisdiction. The complaint of the
plaintiffs in this case did not contain any averment of assessed value of the property. The failure to
alleged the assessed value bereft the RTC from taking cognizance of the case. Thus, the RTC could not
proceed with the trial and should have dismissed the case.
17. Malano vs. Tappa

FACTS: Petitioners Carmen Danao Malana et.al. alleged that they are owners of a parcel of land in
Tugegarao by virtue of inheritance from Anastacio Danao. During Anastacio’s lifetime, he allowed
Consuelo Pauig to build on and occupy the southern portion of the subject property. They both agreed
to vacate the land any time when Anastacio or his heirs might need it. Upon Consuelo’s death, Benigno
Tappa et.al. continued to occupy the subject property. The heirs of Anastacio found out that Tappa et.al.
were claiming ownership over the subject property.

In the Lupong Tagapamayapa, Tappa et.al. presented documents supporting their claim of
ownership. The heirs of Anastacio opposed, claiming that the documents were falsified. Due to the
cloud in title, the heirs of Anastacio filed a complaint for Reinvidication, Quieting of Title, and Damages
with the RTC. Before the respondents could file an answer, the RTC, motu proprio, dismissed the case
for lack of jurisdiction.

ISSUE: Whether or not the dismissal is proper

HELD: Yes. BP 129 provides that the MTC shall have exclusive original jurisdiction over all civil actions
which involve title to, possession of, real property where the assessed value does not exceed P20,000.
As found by the RTC, the assessed value of the subject property as stated in the Tax Declaration is only
P410.00. Thus, the complaint falls within the jurisdiction of the MTC, not the RTC.

If the court has no jurisdiction over the nature of the action, it may dismiss the same ex mero
motu or motu proprio, as held in Laresma vs. Abellana. Thus the dismissal made by the RTC is proper.

*the SC ordered the RTC to remand the records to the MTC or the court of proper jurisdiction for proper
disposition.

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