Title
Genesis Investment, Inc. vs. Heirs of Ebarasabal
Case
G.R. No. 181622
Decision Date
Nov 20, 2013
Heirs contested sale of undivided property by co-heirs, seeking annulment of deed, recovery of shares, and partition; SC upheld RTC jurisdiction, ruling annulment as principal action, incidental to recovery and partition.

Case Digest (A.C. No. 1245)
Expanded Legal Reasoning Model

Facts:

  • Parties and Nature of the Case
    • The petitioners are Genesis Investment, Inc., Cebu Jaya Realty Inc., and Spouses Rhodora and Lambert Lim.
    • The respondents consist of various heirs of the deceased members of the Ebarsabal family, including heirs of Ceferino, Floro, Leona, Pedro, Isidoro, Benito, and Julian Ebarsabal.
    • The case arises from a complaint filed by the respondents seeking multiple reliefs such as:
      • Declaration of nullity of documents (namely, the Deed of Extrajudicial Settlement with Sale and the Memorandum of Agreement).
      • Recovery of shares and partition of a parcel of land.
      • Damages, including moral and exemplary damages, attorney’s fees, and other related costs.
  • Chronology of Proceedings
    • November 12, 2003 – Respondents filed a complaint before the Regional Trial Court (RTC) of Barili, Cebu, asking for:
      • Declaration of nullity of documents.
      • Recovery of their title, interest, and share over a parcel of land.
      • Partition of the property.
      • Damages and attorney’s fees.
    • August 5, 2004 – Petitioners filed a Motion to Dismiss asserting that:
      • The RTC has no jurisdiction on the ground that the disputed property’s assessed value (P11,990.00) falls below the jurisdictional threshold for the RTC in cases involving title or possession of real property.
      • The case should instead be tried by the Municipal Trial Court (MTC) as per the applicable value limits.
    • September 29, 2004 – The RTC issued an Order granting petitioners’ Motion to Dismiss based on:
      • The assessment value as determinative of the proper jurisdiction.
      • The notion that the case was primarily for recovery of shares within the stipulated pecuniary limit.
    • Subsequent Developments in the RTC
      • Respondents filed a Motion for Partial Reconsideration arguing that:
        • The main cause of action (declaration of nullity of documents) is inherently incapable of pecuniary estimation.
ii. Despite involving ancillary claims for title and possession, the principal relief is non-monetary in nature.
  • March 17, 2005 – The RTC reversed its earlier dismissal, thereby finding jurisdiction over the case on the basis that:
    • The primary action was for nullification of the extrajudicial settlement and related documents.
ii. Other claims (recovery of shares and partition) were incidental to the main relief sought.
  • Petitioners filed a Motion for Reconsideration before the RTC, which was denied on June 23, 2005.
  • Appeals to Higher Courts
    • Petition for Certiorari to the Court of Appeals (CA)
      • Petitioners sought to overturn the RTC’s ruling granting jurisdiction, contending that the complaint predominantly claimed recovery of property whose assessed value is within the MTC’s jurisdiction.
    • July 11, 2007 – The CA issued a Decision dismissing petitioners’ arguments by reaffirming that:
      • The principal relief relates to nullification of documents, which is non-pecuniary in nature and thus falls within the RTC’s exclusive jurisdiction.
    • January 10, 2008 – The CA issued a Resolution denying petitioners’ Motion for Reconsideration.
  • Factual Background on the Disputed Property
    • The dispute involves a parcel of land in Basdaku, Saavedra, Moalboal, Cebu.
    • The historical context includes:
      • Originally acquired by Roman Ebarsabal with an assessed value that significantly increased over the years (from P2,890.00 to P11,990.00 by 2002).
      • Upon his death, the property passed to his children by hereditary succession.
    • Controversial Transactions
      • On January 28, 1997, a Deed of Extrajudicial Settlement with Sale was executed among the children and descendants of Gil Ebarsabal.
      • The deed involved the sale of the entire property to Genesis Investment, Inc., represented by Rhodora Lim, despite the plaintiffs’ (other co-heirs) interests not being duly represented or included in the consent.
      • A subsequent issuance of the Tax Declaration in the name of Cebu Jaya Realty, Inc. further complicated matters.

Issues:

  • Jurisdictional Inquiry
    • Whether the Court of Appeals erred in concluding that the RTC of Barili, Cebu had jurisdiction over the case, despite petitioners arguing that the assessed value of the disputed property (P11,990.00) falls within the Municipal Trial Court’s jurisdiction.
  • Nature of the Principal Relief
    • Whether the complaint, which comprises both actions for the recovery of a sum of money (or property interest) and the declaration of nullity of documents, is primarily one of non-pecuniary estimation, thereby conferring jurisdiction on the RTC rather than the MTC.
  • Validity and Implications of the Extrajudicial Settlement
    • Whether the extrajudicial settlement and related documents executed among some co-heirs are binding on the absent co-owners who did not consent to the sale.
    • The impact of such documents on the rights of the plaintiffs as co-owners of the disputed property.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)
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