Elmer Montero vs Santiago Montero, Jr.

G.R. No. 217755 – 863 Phil. 413 – Remedial Law – Civil Procedure – Jurisdiction of Courts; In actions for annulment of title, the assessed value of the subject property is jurisdictional

In 1993, Elmer Montero discovered that Santiago Montero, Jr., through an Affidavit of Self-Adjudication, appropriated unto himself a lot in Pilar, Abra, that Santiago supposedly co-owns with Elmer and others. Santiago made it appear in the affidavit that he is the sole heir to the property and had effectively excluded the other co-heirs / co-owners. As such, the previous tax declaration was cancelled and a new one was issued in the name of Santiago. Santiago was also able to obtain an Original Certificate of Title over the subject property.

Elmer then filed a Complaint for the Annulment of the Affidavit of Self-Adjudication and all other documents issued as a result thereof. Elmer filed his complaint with the Regional Trial Court.

Santiago filed a motion to dismiss on the ground that the RTC has no jurisdiction because the assessed value of the property is merely Php3,. Santiago averred that under the Batas Pambansa Blg. 129, as amended by Republic Act No. 7691, the Metropolitan Trial Courts, Municipal Trial Courts and Municipal Circuit Trial Courts have exclusive original jurisdiction in all civil actions which involve title to, or possession of, real property, or any interest therein where the assessed value of the property or interest therein does not exceed P20,.

The RTC denied the motion on the ground that the action filed by Elmer is one for annulment of title / document which is incapable of pecuniary estimation which is within the jurisdiction of the RTC.

Santiago then filed a certiorari petition under Rule 65 and the Court of Appeals reversed the decision of the RTC.

ISSUE: Whether or not the jurisdiction over an action for annulment of title / document pertaining to a real property is determined by the assessed value.

HELD: Yes. The assessed value in such cases is jurisdictional.

An action “involving title to real property” means that the plaintiff’s cause of action is based on a claim that he or she owns such property or that he or she has the legal rights to have exclusive control, possession, enjoyment, or disposition of the same. Even if the action is supposedly one for annulment of a deed, the nature of an action is not determined by what is stated in the caption of the complaint but by the allegations of the complaint and the reliefs prayed for. Where the ultimate objective of the plaintiffs is to obtain title to real property, it should be filed in the proper court having jurisdiction over the assessed value of the property subject thereof.

In this case, Elmer was seeking for Santiago to respect the right of ownership and possession over the land in question by the heirs of their common ancestor. In fact, Elmer himself declares in his appeal before the Supreme Court that “the narration on the complaint would show that Elmer was only establishing his rightful ownership over the subject property.”

Simply stated, at the heart of Elmer’s Complaint is his assertion of the right of ownership and possession over the subject property as against Santiago’s. Primarily, Elmer seeks to establish and confirm his supposed “rightful ownership” over the subject property.

The SC emphasized that, in a number of cases, it was already held that actions for reconveyance of or for cancellation of title to or to quiet title over real property are actions that fall under the classification of cases that involve “title to, or possession of, real property, or any interest therein.” Hence, Elmer’s case is clearly one involving title to, possession of, and interest in real property.

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NOTE: The jurisdiction of MTCs, MeTCs, MCTCs, has been expanded by Republic Act No. 11576. Hence, for actions involving title or possession of real property, or any interest therein, MTCs, MeTCs, and MCTCs have jurisdiction if the assessed value of the subject lot does not exceed Php400,.