BARANGAY PIAPI V.

TALIP
SEPTEMBER 7, 2005 | SANDOVAL-GUTIERREZ, J. | JURISDICTION > PAYMENT OF DOCKET FEES

PETITIONERS: Barangay Piapi, herein represented by its chairman Andres Lugnasin and 30 others
RESPONDENTS: Ignacio Talip representing the heirs of Juan Jayag
SUMMARY: Petitioners filed in RTC for reconveyance over 3.2ha land and only alleged market value. Case was dismissed for lack
of jurisdiction as they did not allege assessed value which was P6,030 and MCTC has jurisdiction over property of this value.
DOCTRINE: What determines jurisdiction is the allegations in the complaint and the reliefs prayed for. The complaint is for
reconveyance of a parcel of land, which involves the title to or interest in real property and requires that assessed value be alleged.
FACTS:
1. On August 28, 1998, petitioners filed with the RTC Davao a complaint for reconveyance and damages for a 3.2ha parcel of land
with market value of P15,000 in Piapi, Davao del Sur, covered by OCT in the name of Juan Jayag. They allege that they have
openly possessed such land for 30 years in the concept of owner, and that respondent fraudulently obtained a TCT in his name.
2. Respondent filed motion to dismiss. He says the RTC has no jurisdiction over the case as that the assessed value of the land is
P6,030.00. Under Section 33 (3) of BP 129, as amended by RA 7691, Municipal Circuit Trial Court has exclusive jurisdiction.
3. Petitioners alleged that jurisdiction is vested in the RTC as that the total assessed value of the property is P41,890.00, per a Real
Property Field Appraisal and Assessment Sheet dated August 20, 1996 issued by the Provincial Assessor of Davao del Sur.
4. RTC Davao dismissed the complaint for lack of jurisdiction hence this certiorari petition saying that Section 19 (1) of BP Blg.
129, as amended, gives the RTC jurisdiction over the complaint for reconveyance since it is incapable of pecuniary estimation.
ISSUE:
Whether the RTC has jurisdiction over the complaint for reconveyanceNO, the Municipal Circuit Trial Court of Davao del Sur has
jurisdiction over the case for failure to allege the propertys assessed value
HELD:

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. However, they failed to allege therein the assessed value of the
subject property. Instead, what they stated is the market value of the land at P15,000.00.

Huguete vs. Embudo: Analogous case where petitioners argued that a complaint for annulment of a deed of sale and partition is
incapable of pecuniary estimation, and thus falls within the exclusive jurisdiction of the RTC. SC ruled that the nature of an action
is not determined by the caption of the complaint but by the allegations of the complaint and the reliefs prayed for.
RULES:
Section 19 (2) of Batas Pambansa Blg. 129. Jurisdiction in civil cases. RTCs shall exercise exclusive original jurisdiction:
(2) In all civil actions which involve the title to, or possession of, real property, or any interest thereon, where the assessed value of the property
involved exceeds Twenty thousand pesos (P20,000.00) or for civil actions in Metro Manila, where such value exceeds Fifty thousand pesos
(P50,000.00) except actions for forcible entry into and unlawful detainer of lands or buildings, original jurisdiction over which is conferred upon the
Metropolitan Trial Courts, Municipal Trial Courts, and Municipal Circuit Trial Courts.
Section 33. Jurisdiction of Metropolitan Trial Courts, Municipal Trial Courts and Municipal Circuit Trial Courts in Civil Cases. Metropolitan Trial
Courts, Municipal Trial Courts, and Municipal Circuit Trial Courts shall exercise:
(3) 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 Twenty thousand pesos (P20,000.00) or, in civil actions in Metro Manila, where such
assessed value does not exceed Fifty thousand pesos (P50,000.00) exclusive of interest, damages of whatever kind, attorneys fees, litigation expenses
and costs: Provided, That in cases of land not declared for taxation purposes, the value of such property shall be determined by the assessed value of
the adjacent lots.