G.R. No. 135038 - Tan vs. Court of Appeals

On August 10, 1999, spouses Generoso and Aurelia Sebe and their daughter Lydia (collectively, the Sebes) filed in the Regional Trial Court (RTC) of Dipolog City, Branch 9, Civil Case No. 5435, a complaint for:

Annulment of documents (affidavits of quitclaim and deeds of confirmation of sale)
Reconveyance of title
Recovery of possession over two lots
Damages (lost produce, moral, exemplary, litigation expenses, attorney’s fees)

The two lots, located in Dampalan, San Jose, Dipolog City, were unregistered but covered by Tax Declaration No. 012-239 with a combined assessed value of ₱9,910.00.

The Sebes claimed 40-year undisputed ownership of the lots; on June 3, 1991, respondent Veronico Sevilla induced them to sign “affidavits of quitclaim,” misrepresenting them as real estate mortgage documents.
Without the Sebes’ personal appearance, the documents were notarized. On September 23, 1991, Sevilla secured free patent titles in his name and later mortgaged the lots to Technology and Livelihood Resource Center for ₱869,555.00.
On December 24, 1991, deeds of confirmation of sale were presented, with signatures apparently forged. Sevilla thereafter declared the lots for taxation, forcibly ousted tenants, and harvested produce worth about ₱20,000.00.
The Sebes incurred litigation expenses, lost earnings, and sought compensation for moral and exemplary damages.

On August 8, 2006, the RTC dismissed the complaint for lack of jurisdiction, reasoning that actions involving real property with assessed value below ₱20,000.00 fall under the exclusive original jurisdiction of Municipal Trial Courts (MTCs).
The Sebes moved for reconsideration, contending that their action was one “incapable of pecuniary estimation” (citing De Rivera v. Halili and Copioso v. Copioso), thus within RTC jurisdiction under Section 19 of Batas Pambansa 129, as amended by R.A. 7601.
On August 31, 2006, the RTC denied reconsideration, observing that Copioso was overruled by Spouses Huguete v. Spouses Embudo and reaffirming that jurisdiction depended on the assessed value threshold.
The Sebes filed a petition for review on certiorari before the Supreme Court.

Whether the Sebes’ action—seeking annulment of fraudulent conveyance documents, reconveyance of title, recovery of possession, and damages—qualifies as an action “incapable of pecuniary estimation” under Section 19 of B.P. 129 (as amended), thus within the exclusive original jurisdiction of the RTC, despite the assessed value being ₱9,910.00.
Or whether it is an action “involving title to, or possession of, real property” whose jurisdiction rests on the assessed-value threshold, thereby falling under the MTC.