G.R. No. 149554 - Spouses Huguete vs. Spouses Embudo

The petition for review arose from orders dated June 27, 2001, and July 26, 2001, issued by the Regional Trial Court (RTC) of Cebu City, Branch 7 in Civil Case No. CEB-24925.
Petitioners, spouses Jorge J. Huguete and Yolanda B. Huguete, filed a complaint on March 2, 2000, against respondents, spouses Teofredo Amarillo Embudo and Marites Huguete-Embudo, seeking annulment of documents and partition related to a parcel of land.
The complaint alleged irregularities in the sale and partition of a 50-square meter portion of a 150-square meter lot (Lot No. 1920-F-2) located in San Isidro, Talisay, Cebu, purchased for P15,000.00.

Petitioners contended that respondent Teofredo sold a portion of the land to them at the price of P15,000.00, although Teofredo had acquired a Transfer Certificate of Title (TCT No. 99694) solely in his name after buying the property from Ma. Lourdes Villaber-Padillo.
It was further alleged that despite repeated demands, respondents refused to partition the lot, thereby depriving petitioners of their rightful share and title.
The complaint sought the annulment and cancellation of the deed of sale, partition of property, cancellation of the existing title, and issuance of new titles corresponding to the segregated portions.

On March 15, 2001, respondents filed a Motion to Dismiss the complaint on the ground of lack of jurisdiction, arguing that the subject matter, with an assessed value of P15,000.00, fell under the exclusive jurisdiction of Municipal Trial Courts (MTC) pursuant to Section 33(3) of Batas Pambansa Blg. 129, as amended by Republic Act No. 7691.
Petitioners opposed the motion, contending that the subject matter was “incapable of pecuniary estimation” and should fall within the jurisdiction of the RTC under Section 19(1) of the same law.
The RTC dismissed the complaint based on its interpretation of jurisdiction and later denied petitioners’ Motion for Reconsideration on July 26, 2001.

The partition, division, and segregation of a 50-square meter portion of the lot where their house was built.
Annulment and cancellation of the deed of sale and the corresponding Transfer Certificate of Title.
Issuance of a new Transfer Certificate of Title in the name of petitioners for the 50-square meter portion, with a separate title for the remaining 100-square meter lot in the name of respondents.

The complaint further included allegations of fraudulent conduct, indicating that respondents had concealed the true state of the Deed of Sale and the title registration from petitioners.
Petitioners referenced settled jurisprudence, notably Russell v. Vestil, to support their claim that the action was inherently “incapable of pecuniary estimation.”

Whether the RTC has proper jurisdiction over the complaint given that the subject matter allegedly involves annulment of a deed and partition of real property.
Whether an action for annulment of title and partition, despite its characterization, is capable or incapable of pecuniary estimation.

Whether Section 33(3) of Batas Pambansa Blg. 129 (as amended) mandates that the case fall exclusively under the jurisdiction of the Municipal Trial Court due to the assessed property value.
Whether Section 19(1) of the same law, along with settled case law, provides the activation of RTC jurisdiction in cases where the subject matter is not amenable to pecuniary estimation.

Whether respondents, by seeking affirmative relief and invoking the authority of the court in their counterclaim, are estopped from denying the court’s jurisdiction over the subject matter.