Case Digest (G.R. No. 85339) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In EULALIA RUSSELL et al. v. HON. AUGUSTINE A. VESTIL et al., decided March 17, 1999, petitioners filed on September 28, 1994 before the Regional Trial Court (RTC) of Mandaue City, Branch 56, Civil Case No. MAN-2275, a complaint entitled “Declaration of Nullity and Partition.” They alleged co-ownership with private respondents of Lot 6149 in Liloan, Cebu (56,977.40 sq. m.; assessed at ₱5,000), inherited from spouses Casimero and Cesaria Tautho. Petitioners claimed that private respondents executed on June 6, 1990 a Declaration of Heirs and Deed of Confirmation of a Previous Oral Agreement of Partition falsely excluding petitioners, procured tax declarations over their supposed shares, and thereby prejudiced petitioners’ share. They prayed that the deed be annulled and the land partitioned among all heirs, with attorney’s fees. Private respondents moved to dismiss for lack of jurisdiction, invoking Section 33(3) of Batas Pambansa Blg. 129 (as amended by R.A. 7691), since the Case Digest (G.R. No. 85339) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Subject Property
- Petitioners: Eulalia Russell, Ruperto Tautho, Francisco Tautho, Susana T. Reales, Apitacio Tautho, Danilo Tautho, Juditha Pros, Gregorio Tautho, Deodita T. Judilla, Agripino Tautho, Felix Tautho, William Tautho, and Marilyn Perales.
- Respondents: Hon. Augustine A. Vestil (RTC Judge), Adriano Tagalog, Marcelo Tautho, Juanita Mendoza, Domingo Bantilan, Raul Bataluna, and Artemio Cabatingan.
- Property: Lot 6149 in Cotcot, Liloan, Cebu, containing 56,977.40 sqm, formerly owned by spouses Casimero and Cesaria Tautho, now undivided among their heirs.
- Origin of Dispute
- June 6, 1990: Respondents executed a “Declaration of Heirs and Deed of Confirmation of a Previous Oral Agreement of Partition,” dividing the land among themselves and excluding petitioners.
- Petitioners discovered the document and filed on September 28, 1994 a complaint for nullity of that deed and for partition among all heirs.
- Procedural History
- November 24, 1994: Respondents moved to dismiss for lack of jurisdiction—asserting assessed value of P5,000 falls under MCTC jurisdiction (Sec. 33[3], B.P. 129).
- January 12, 1995: RTC Branch 56 granted the motion and dismissed the complaint.
- January 30, 1995: Petitioners filed a motion for reconsideration, arguing the action is for annulment of a document (incapable of pecuniary estimation) and thus within RTC jurisdiction (Sec. 19[1], B.P. 129).
- February 13, 1995: RTC denied the motion for reconsideration.
- Petitioners filed a Petition for Certiorari with the Supreme Court to set aside both orders.
Issues:
- Does the Regional Trial Court have jurisdiction over Civil Case No. MAN-2275?
- Petitioners’ position: The action is primarily for annulment of a document (incapable of pecuniary estimation) and thus under RTC’s exclusive original jurisdiction (Sec. 19[1], B.P. 129).
- Respondents’ position: The action is one for re-partition of property valued at P5,000, falling under MCTC jurisdiction (Sec. 33[3], B.P. 129, as amended).
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)