Copioso vs. Copioso

Where a complaint joins causes of action that are incapable of pecuniary estimation — such as annulment of sale, reconveyance, and damages — the Regional Trial Court has jurisdiction even if the assessed value of the subject real property falls within the exclusive original jurisdiction of the Municipal Trial Court.

Respondents Lauro, Dolores, Rafael, Esteban, and Corazon, all surnamed Copioso, together with their deceased brother Antonio Copioso, were co-owners of two parcels of coconut land in Banilad, Nagcarlan, Laguna, having inherited the same from their parents. The jurisdictional framework governing trial courts in civil cases is found in B.P. Blg. 129 (The Judiciary Reorganization Act of 1980), as amended by R.A. No. 7691, which allocates jurisdiction between the MTC and RTC based on either the assessed value of real property or the capability or incapability of pecuniary estimation of the action.

On 4 July 2000, respondents Lauro, Dolores, Rafael, Esteban, and Corazon, all surnamed Copioso, filed a complaint for "Reconveyance and/or Recovery of Common Properties Illegally Disposed, with Annulment of Sales and other Instruments of False Conveyance, with Damages, and Restraining Order" against Lolita B. Copioso, spouses Bernabe and Imelda Doria, the estate of deceased Antonio Copioso, and vendees Dolores Reduca, Mercedes Reduca, Rosario Pascua, Elvira Bombasi, and Federico Casabar. The complaint concerned two parcels of coconut land situated in Banilad, Nagcarlan, Laguna. 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.

According to the complaint, in or about 1998, through fraud and machination, Antonio Copioso together with spouses Bernabe and Imelda Doria made it appear in a public document entitled "Pagpapatunay ng Kusang Loob na Pagbabahagi" that they were the co-owners of the subject property and had divided the same equally between themselves, to the exclusion of private respondents. Subsequently, they sold the subdivided lots to the other defendants — Dolores Reduca, Mercedes Reduca, Rosario Pascua, Elvira Bombasi, and Federico Casabar.

Respondents sought payment of moral damages, exemplary damages, litigation expenses, attorney's fees plus appearance fees amounting to more or less ₱286,500.00. They likewise applied for a temporary restraining order pending the issuance of a writ of preliminary injunction restraining the defendants from further alienating the common properties. They also prayed that the trial court order the cancellation, annulment, and/or rescission of four deeds of absolute sale made in favor of the buyers, and order Lolita B. Copioso and the estate of Antonio Copioso to return the price that the buyer-defendants had paid for the land sold.

When respondents claimed in a manifestation with motion for bill of particulars that the assessed value of the subject property was ₱3,770.00, petitioner Lolita Copioso and spouses Bernabe and Imelda Doria separately moved to dismiss the complaint on the ground that it was the MTC, not the RTC, that had jurisdiction, the assessed value being below ₱20,000.00. The trial court denied the motions to dismiss in its twin orders of 5 and 12 September 2000, holding that since the subject matter of the action was beyond pecuniary estimation, it was properly within the RTC's jurisdiction. Petitioner's motion for reconsideration was likewise denied.

• Jurisdiction Based on Assessed Value: Petitioner argued that under Section 33, paragraph (3) of B.P. Blg. 129, as amended by Section 3 of R.A. No. 7691, the MTC has exclusive original jurisdiction over civil actions involving title to, possession of, or any interest in real property where the assessed value does not exceed ₱20,000.00. She maintained that the complaint for reconveyance could not be resolved without delving into the issues of title, possession, and interests of each stakeholder over the subject parcels of land, and that the allegations and relief prayed for, coupled with the assessed value of ₱3,770.00, placed the action within the exclusive jurisdiction of the MTC.

• Jurisdiction Based on Incapability of Pecuniary Estimation: Respondents anchored their position on Section 19, paragraph (1) of B.P. Blg. 129, which vests in the RTC exclusive original jurisdiction over civil actions in which the subject of the litigation is incapable of pecuniary estimation. They claimed that the complaint for reconveyance was a case of joinder of causes of action which included the annulment of sale and other instruments of false conveyance — matters incapable of pecuniary estimation — thus within the legal competence of the RTC.

• Jurisdiction: Whether the Regional Trial Court, and not the Municipal Trial Court, has jurisdiction over a complaint for reconveyance where the assessed value of the subject property is below ₱20,000.00 but the complaint joins causes of action incapable of pecuniary estimation.

• Jurisdiction: Yes. The RTC has jurisdiction. Where a complaint involves a joinder of causes of action that includes annulment of contracts, reconveyance, and a claim for damages — all incapable of pecuniary estimation — jurisdiction lies with the RTC notwithstanding that the assessed value of the real property falls within the MTC's jurisdictional threshold.

• Jurisdiction: The law on jurisdiction of trial courts over civil cases distinguishes between cases capable of pecuniary estimation, where jurisdiction is determined by the amount of the claim or assessed value of the property (Section 33(3) in relation to Section 19(2) of B.P. Blg. 129, as amended by R.A. No. 7691), and cases incapable of pecuniary estimation, where jurisdiction lies with the RTC regardless of assessed value (Section 33(3) in relation to Section 19(1)). The complaint filed by private respondents was captioned "Reconveyance and/or Recovery of Common Properties Illegally Disposed, with Annulment of Sales and other Instruments of False Conveyance, with Damages, and Restraining Order." It alleged fraud and machination in the execution of a public document purporting to divide the property to the exclusion of respondents, sought annulment and rescission of four deeds of absolute sale, and claimed moral and exemplary damages, attorney's fees, and litigation expenses amounting to approximately ₱286,500.00. This constituted a joinder of causes of action comprehending more than the issue of title, possession, or interest in real property — it included an action to annul contracts, reconveyance, and a claim for damages, all incapable of pecuniary estimation. Had the only issue been naked possession or bare ownership, the MTC would have had jurisdiction given the assessed value of ₱3,770.00. But because the issue of title, ownership, and possession was intertwined with the issue of annulment of sale and reconveyance, the action fell within the ambit of the RTC's jurisdiction. The assessed value of the parcels of land thus became merely an incidental matter in the resolution of the case, not determinative of jurisdiction.

• Jurisdiction over actions incapable of pecuniary estimation — Where the subject of litigation is incapable of pecuniary estimation, the RTC has exclusive original jurisdiction under Section 19(1) of B.P. Blg. 129, regardless of the assessed value of any real property involved. Actions for annulment of contracts, reconveyance, and damages are incapable of pecuniary estimation. In this case, the complaint joined these causes of action with the issue of title and possession, thereby placing the case within the RTC's jurisdiction notwithstanding the property's low assessed value.

• Joinder of causes of action and jurisdiction — Where a complaint comprehends a joinder of causes of action, some capable and others incapable of pecuniary estimation, the nature of the action as a whole — determined by the allegations, the reliefs prayed for, and the character of the causes of action joined — controls the question of jurisdiction. The assessed value of the property becomes merely incidental and not jurisdictional when the primary causes of action are incapable of pecuniary estimation.

• "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." — This passage states the ratio decidendi: the joinder of causes of action incapable of pecuniary estimation places the case within RTC jurisdiction regardless of assessed value.

• "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." — This formulation clarifies that assessed value is not the controlling factor when the action is incapable of pecuniary estimation, a principle frequently cited in subsequent jurisdictional disputes.

• Section 33(3), B.P. Blg. 129 (The Judiciary Reorganization Act of 1980), as amended by Section 3, R.A. No. 7691 — Grants MTCs exclusive original jurisdiction over civil actions involving title to, possession of, or any interest in real property where the assessed value does not exceed ₱20,000.00 (₱50,000.00 in Metro Manila). Petitioner invoked this provision to argue MTC jurisdiction, but the Court held it inapplicable because the complaint joined causes of action incapable of pecuniary estimation.

• Section 19(1), B.P. Blg. 129 — Vests RTCs with exclusive original jurisdiction over civil actions in which the subject of the litigation is incapable of pecuniary estimation. The Court applied this provision to uphold RTC jurisdiction, finding that the annulment of sale, reconveyance, and damages claims were incapable of pecuniary estimation.

• Section 19(2), B.P. Blg. 129, as amended by R.A. No. 7691 — Vests RTCs with exclusive original jurisdiction over civil actions involving title to, possession of, or any interest in real property where the assessed value exceeds ₱20,000.00 (₱50,000.00 in Metro Manila). The Court cited this provision in explaining the jurisdictional framework for cases capable of pecuniary estimation, contrasted with the present case.

Mendoza, J., and Quisumbing, J., concurred. Austria-Martinez, J., was on leave.