G.R. No. 149243 - Copioso vs. Copioso

Petitioner Lolita B. Copioso is challenging the decision of the Court of Appeals which dismissed her petition for certiorari and denied her motion for reconsideration regarding jurisdiction.
The case arose from a complaint for reconveyance of two parcels of coconut land situated in Banilad, Nagcarlan, Laguna filed by respondents (Lauro, Dolores, Rafael, Esteban, and Corazon Copioso) on 4 July 2000.

Respondents alleged that they, together with their deceased brother Antonio Copioso, were the co-owners of the disputed property inherited from their parents.
They claimed that through fraud and machination, Antonio Copioso transferred the property to his name and further to spouses Bernabe and Imelda Doria, who then sold the property to third-party vendees (Dolores Reduca, Mercedes Reduca, Rosario Pascua, Elvira Bombasi, and Federico Casabar).
The complaint prayed for the reconveyance of the property based on their co-ownership rights, along with other reliefs including annulment of alleged false conveyance instruments, damages, and a temporary restraining order (TRO).

Petitioner Lolita Copioso, along with spouses Bernabe and Imelda Doria, filed motions to dismiss the complaint on the ground that the assessed value of the property (P3,770.00) fell within the exclusive jurisdiction of the Municipal Trial Court (MTC) rather than the Regional Trial Court (RTC).
The trial court denied the motions to dismiss on 5 and 12 September 2000, holding that the subject matter, being beyond mere pecuniary estimation, fell under the jurisdiction of the RTC.

After the denial of her motion for reconsideration by the trial court, petitioner Lolita Copioso elevated the issue by filing a petition for certiorari and prohibition before the Court of Appeals.
Petitioner argued that because the case involves issues of title, possession, and interests amounting to a property assessed at P3,770.00, the complaint should be under the exclusive jurisdiction of the MTC.
The Court of Appeals, however, denied the petition, affirming that the nature of the action comprises joinder of causes of action that exceed simple matters of pecuniary estimation.

Anchored on Section 33, paragraph (3) of B.P. Blg. 129 (The Judiciary Reorganization Act of 1980 as amended by RA 7691), which confines the exclusive original jurisdiction of Metropolitan, Municipal, and Municipal Circuit Trial Courts in civil cases involving title to, or possession of, real property with an assessed value not exceeding P20,000.00 (or P50,000.00 in Metro Manila).
Argued that the comprehensive issues in the complaint (involving title, possession, and interests) should be resolved by the MTC given the assessed value of the disputed property.

Grounded on Section 19, paragraph (1) of B.P. 129, which provides that Regional Trial Courts have exclusive original jurisdiction in civil cases involving subjects that are "incapable of pecuniary estimation."
Contended that the joinder of causes of action, which include issues such as annulment of sale, reconveyance, and damage claims, unquestionably places the case beyond the jurisdiction of the MTC.

Whether the subject matter of the complaint – involving reconveyance, annulment of sale, and recovery of common properties allegedly disposed of by fraud – falls within the exclusive jurisdiction of the Municipal Trial Court (MTC) based on the assessed value of the property.
Whether the joinder of causes of action that include actions typically incapable of pecuniary estimation, such as annulment of sale and claims for damages, necessitates the jurisdiction of the Regional Trial Court (RTC) regardless of the assessed value.

How to correctly interpret Section 33, paragraph (3), vis-à-vis Section 19, paragraphs (1) and (2) of B.P. Blg. 129 as amended by RA 7691 in determining the appropriate forum for civil actions involving real property disputes.
Whether the nature and reliefs prayed in the complaint transform a simple matter of property reconveyance into a complex, multi-issue case beyond mere pecuniary valuation.

Whether the assessed value of the property is a determinative element in deciding jurisdiction or merely incidental to resolving the intertwined issues of title, possession, annulment of sale, and damages.