Copioso Vs Copioso, 391 SCRA 325 GR No. 149243, October 28, 2002

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Copioso vs Copioso, 391 SCRA 325; GR No.

149243, October 28, 2002


(Civil Procedures – Jurisdiction; Civil actions in which the subject of the litigation is incapable of
pecuniary estimation)

Facts: Respondents filed with the RTC an action for specific performance of reconveyance of two parcels
of land having an assessed value of P3,770.00.

Respondents alleged that they together with their deceased brother were co-owners of the subject
property having inherited the same from their parents, and that through fraud and machination the
deceased had the property transferred to his name and that of spouses Doria who subsequently sold the
same to third parties.  Thus, they are  praying for the reconveyance of the property by virtue of their
being co-owners thereof.

Petitioners moved to dismiss the complaint on that ground that it was the MTC and not the RTC that had
jurisdiction considering that the assessed value of the property was lower than P20,000.00 (Section 33
[3] of Batas Pambansa Blg. 129, as amended by R.A. No. 7691). Petitioners argue that the complaint for
reconveyance cannot be resolved unless the trial court delves upon the issues of “title, possession and
interests” of each of the stakeholders over the subject parcels of land.

Respondents claim that the instant complaint for reconveyance is a case of joinder of causes of action
which include the annulment of sale and other instruments of false conveyance incapable of pecuniary
estimation thus within the legal competence of the RTC ( Section 19(l) of B.P. 129, as amended).

The trial court denied the motion to dismiss holding that since the subject matter of the action was
beyond pecuniary estimation it was properly within its jurisdiction.

Issue: WON denial of the motion to dismiss was correct.

Held: Yes. Although the assessed value of the two parcels of land involved is P3,770.00, which is within
the jurisdiction of the MTC, the action filed by the respondents is for specific performance of
reconveyance, annulment of contracts and claim for damages, which are incapable of pecuniary
estimation and thus properly within the jurisdiction of the RTC.

If the action affects the title to or possession of real property then it is a real action and jurisdiction is
determined by the assessed value of the property. It is within the jurisdiction therefore of the
Metropolitan Trial Court.

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