G.R. No. 169757 - Lirio vs. Genovia

Petitioner Barangay San Roque, Talisay, Cebu filed a Complaint for Eminent Domain in MTC Talisay, Branch 1.
On April 8, 1997, the MTC dismissed the Complaint for lack of jurisdiction, holding that expropriation suits fall within the exclusive original jurisdiction of the Regional Trial Courts (RTCs) as actions “incapable of pecuniary estimation.”

Petitioner filed the Complaint anew in RTC Cebu City, Branch 58, which, on March 29, 1999, granted respondents’ motion to dismiss for lack of jurisdiction. The RTC held that because the assessed value of the property was ₱1,740.00 (below ₱20,000.00), the case belonged in the MTC under Section 3(3), R.A. 7691, as an action affecting title to or possession of real property.
On May 14, 1999, the RTC denied petitioner’s motion for reconsideration, reiterating its view that the assessed value governed jurisdiction.

Petitioner filed a Petition for Review on Certiorari before the Supreme Court, but it was initially dismissed as filed out of time (Resolution of July 28, 1999) and later reinstated (Resolution of October 6, 1999).
The sole issue framed: “Which court, MTC or RTC, has jurisdiction over cases for eminent domain or expropriation where the assessed value of the subject property is below Twenty Thousand (₱20,000.00) Pesos?”

Whether expropriation (eminent domain) suits are “incapable of pecuniary estimation” and thereby fall under the exclusive original jurisdiction of RTCs pursuant to Section 19(1), Batas Pambansa Blg. 129.
Whether the assessed monetary value of the property (below ₱20,000.00) divests the RTC of jurisdiction in favor of the MTC under Section 3(3), R.A. 7691.