Title
Supreme Court
Montero vs. Montero, Jr.
Case
G.R. No. 217755
Decision Date
Sep 18, 2019
Petitioner Elmer Montero sought nullity of an Affidavit of Adjudication and reconveyance of land, but the Supreme Court ruled the RTC lacked jurisdiction due to the property's assessed value below P20,000, affirming the MTC as the proper forum.

Case Digest (G.R. No. 217755)
Expanded Legal Reasoning Model

Facts:

  • Parties and Complaint
    • Petitioner Elmer Montero filed a Complaint for Declaration of Nullity of Affidavit of Adjudication, Cancellation of Tax Declaration No. 5289 and OCT No. P-14452, Reconveyance, and Damages with Prayer for Preliminary Injunction against respondents Santiago Montero Jr. and Charlie Montero, and several municipal officials in their official capacities.
    • The subject property is a parcel of land in Pilar, Abra formerly covered by Free Patent No. 27941 issued in Dominga Taeza’s name on January 11, 1939.
  • Title and Possession History
    • Dominga Taeza died intestate in 1975, leaving surviving heirs including petitioner Elmer (heir of Alfredo Montero). Upon her death, her estate passed by operation of law to her heirs.
    • In 1989, respondent Santiago executed an Affidavit of Adjudication misrepresenting himself as Dominga’s sole heir, resulting in transfer of Tax Declaration No. 417 to Tax Declaration No. 5289 and issuance of OCT No. P-14452 in his name.
  • Acts of Respondents and Refusal to Reconvey
    • In 2002, respondents threatened heirs and erected constructions on the residential portion of the land.
    • Respondents refused repeated demands to reconvey the property to Dominga’s heirs.
  • RTC Proceedings
    • Respondents filed a Motion to Dismiss for lack of jurisdiction, arguing the assessed value of the property (₱3,010) vested exclusive jurisdiction in the Municipal Trial Court.
    • The RTC denied the motion, ruling the cause incapable of pecuniary estimation as petitioner sought voiding of a Torrens title.
    • Respondents elevated the matter to the Court of Appeals via Rule 65 petition.
  • CA Decision and Subsequent Petition
    • The Court of Appeals granted the Rule 65 petition, set aside the RTC orders, and held that the action involved title to or possession of real property assessed below ₱20,000, thus falling under the exclusive jurisdiction of lower courts.
    • Petitioner Elmer filed a Petition for Review on Certiorari under Rule 45 to challenge the CA’s decision.

Issues:

  • Whether petitioner Elmer’s Complaint principally involves title to, possession of, or interest in real property with an assessed value below ₱20,000, and thus whether the RTC lacked jurisdiction because jurisdiction over such actions is vested in the Municipal Trial Courts.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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