Mendoza vs. Teh

The inclusion of an allegation seeking the appointment of an administratrix in an ordinary action for reconveyance does not oust the Regional Trial Court of its jurisdiction over the case. The Court held that the RTC has exclusive original jurisdiction over actions involving title to real property and matters incapable of pecuniary estimation, such as the appointment of an administratrix. Because the decedent's residence at the time of death affects only the venue of the special proceeding, not the court's jurisdiction over the reconveyance suit, the RTC properly retained jurisdiction over the entire action.

Adelia C. Mendoza filed a complaint for reconveyance of title and damages with a petition for preliminary injunction before the RTC of Batangas, seeking to recover parcels of land located in the province. In her complaint, Mendoza, representing herself and the intestate estate of her late husband Norberto B. Mendoza, alleged that she should be appointed judicial administratrix of the estate. Norberto Mendoza had died on December 29, 1993, and was a resident of Quezon City at the time of his death.

• The Complaint: On October 28, 1994, petitioner Adelia C. Mendoza filed a complaint for "reconveyance of title (involving parcels of lot in Batangas) and damages with petition for preliminary injunction" before the RTC of Batangas. She filed the action for herself and as representative of the intestate estate of her late husband, Norberto B. Mendoza.
• The Allegation on Administratrix: In the complaint, Mendoza alleged that she should be appointed by the court as the judicial administratrix of her husband's estate for purposes of the case, though she did not formally pray for such appointment in the prayer of the complaint.
• The Motion to Dismiss: Private respondents filed a motion to dismiss, arguing lack of jurisdiction, lack of cause of action, estoppel, laches, and prescription. They contended that a special proceeding for the appointment of an administratrix could not be incorporated into an ordinary civil action for reconveyance. They further argued that because Norberto Mendoza resided in Quezon City at the time of his death, the petition for appointment of administratrix should be filed in the RTC of Quezon City pursuant to Section 1, Rule 73 of the Rules of Court, thereby ousting the RTC of Batangas of jurisdiction.
• The RTC Ruling: The RTC, through respondent Judge Teh, dismissed the complaint without prejudice for lack of jurisdiction. The court agreed with respondents that the rules governing ordinary civil actions and special proceedings are different. It found it unnecessary to discuss the other grounds raised in the motion to dismiss.

• Petitioner maintained that the allegation seeking her appointment as administratrix was merely an incidental matter that was not even prayed for in the complaint.
• Petitioner argued that the RTC of Batangas retained jurisdiction over the reconveyance suit regardless of the incidental allegation regarding the administratrix.

• Respondents argued that the RTC lacked jurisdiction because a special proceeding for the appointment of an administratrix cannot be incorporated into an ordinary civil action for reconveyance.
• Respondents contended that because the decedent resided in Quezon City at the time of his death, the appointment of the estate administratrix must be filed in the RTC of Quezon City pursuant to Section 1, Rule 73 of the Rules of Court, thereby depriving the RTC of Batangas of jurisdiction over the case.

• Procedural Issues: Whether an allegation seeking the appointment of an administratrix in an action for reconveyance ousts the Regional Trial Court of its jurisdiction over the entire case.
• Substantive Issues: N/A

• Procedural: The Court ruled that the allegation seeking the appointment of an administratrix did not oust the RTC of its jurisdiction. Under Section 19 of B.P. 129 as amended by R.A. 7691, the RTC exercises exclusive original jurisdiction over civil actions involving title to real property and matters incapable of pecuniary estimation, such as the appointment of an administratrix. The Court clarified that respondents confused jurisdiction with venue. The decedent's residence in Quezon City affects only the venue of the estate proceedings under Section 1, Rule 73, not the RTC's jurisdiction over the reconveyance suit involving property located in Batangas. Furthermore, the RTC was not acting as a probate court; it was exercising its general jurisdiction. Whether the RTC acts in its general or limited probate jurisdiction is a procedural question, not a jurisdictional one. Because the RTC possessed jurisdiction over both the reconveyance suit and the appointment of an administratrix, the dismissal of the entire complaint was improper.
• Substantive: N/A

• Jurisdiction vs. Venue in Estate Proceedings — Jurisdiction over actions involving title to real property and the appointment of an administratrix lies with the Regional Trial Court. The residence of the decedent at the time of death, as provided in Section 1, Rule 73 of the Rules of Court, determines the venue of the settlement of estate proceedings, not the jurisdiction of the court over the subject matter of a reconveyance suit. The Court applied this doctrine to hold that the decedent's Quezon City residence affected only venue, not the RTC of Batangas's jurisdiction over the reconveyance case.
• General vs. Probate Jurisdiction of the RTC — Whether a particular matter should be resolved by the RTC in the exercise of its general jurisdiction or its limited probate jurisdiction is a procedural question, not a jurisdictional issue. The Court applied this principle to clarify that because the action was for reconveyance and not the settlement of an estate, the RTC was exercising its general jurisdiction, and the limitations on a probate court's authority to decide questions of ownership did not apply.

• "By arguing that the allegation seeking such appointment as administratrix ousted the RTC of its jurisdiction, both public and private respondents confuse jurisdiction with venue."
• "The mere fact that petitioner's deceased husband resides in Quezon City at the time of his death affects only the venue but not the jurisdiction of the Court."
• "It should be clarified that whether a particular matter should be resolved by the RTC in the exercise of its general jurisdiction or its limited probate jurisdiction, is not a jurisdictional issue but a mere question of procedure."

• Rodriguez vs. Borja, 17 SCRA 418 (1976) — Cited to support the distinction between jurisdiction and venue, specifically that the residence of the decedent affects venue, not jurisdiction.
• Coca vs. Borromeo, 81 SCRA 278 (1978) — Cited to support the ruling that whether the RTC acts in its general jurisdiction or limited probate jurisdiction is a procedural question, not a jurisdictional issue.
• Guzman v. Anog, 37 Phil. 61 (1917); Ongsingco v. Tan, 97 Phil. 330 (1955); Tagle v. Manalo, 105 Phil. 1124 (1959); Manalo v. Manalo, 65 Phil. 534 (1938); Recto v. Dela Rosa, 75 SCRA 226 (1977); Morales v. CFI of Cavite, 146 SCRA 373 (1986) — Distinguished. These cases involved the settlement of estate where the probate court was asked to resolve questions of ownership, unlike the present case which merely contained an allegation seeking appointment as administratrix in a reconveyance suit.
• Pascual vs. Pascual, 73 Phil. 561 (1942); Alvarez vs. Espiritu, 14 SCRA 892 (1965); Cunanan vs. Amparo, 80 Phil. 227 (1948); Lachenal vs. Salas, 71 SCRA 262 (1966) — Distinguished. These cases established that a probate court cannot generally decide questions of ownership or title to property. The Court held this inapplicable because no settlement of estate was involved and the RTC was not acting as a probate court.

• Section 19, Batas Pambansa Blg. 129 (as amended by Republic Act No. 7691) — Defines the jurisdiction of the Regional Trial Courts in civil cases. The Court applied this provision to establish that the RTC has exclusive original jurisdiction over civil actions involving title to real property or possession thereof, as well as matters incapable of pecuniary estimation such as the appointment of an administratrix.
• Section 33, Batas Pambansa Blg. 129 — Defines the jurisdiction of the Metropolitan Trial Courts. The Court cited this provision to note that probate proceedings fall within the ambit of either the RTC or MTC depending on the net worth of the estate.
• Section 1, Rule 73, Rules of Court — Provides the venue for settlement of estate of deceased persons. The Court applied this rule to clarify that the decedent's residence determines the venue of the estate proceedings, not the jurisdiction of the court over the reconveyance action.
• Section 2, Rule 4, Rules of Court (as revised by Circular 13-95) — Governs venue in the RTC for actions affecting title to real property. The Court applied this rule to determine that the action for reconveyance should be commenced and tried in Batangas, where the property is located.

Narvasa, C.J., Davide, Jr., Melo, and Panganiban, JJ., concur.