Case Summary (G.R. No. 149243)
Factual Background
On July 4, 2000, the respondents filed a complaint for reconveyance against Lolita B. Copioso, spouses Bernabe and Imelda Doria, the estate of Antonio Copioso, and other vendees. They claimed co-ownership of the property, alleging that Antonio Copioso fraudulently transferred the land solely into his name and that of the Doria spouses, who subsequently sold it to third parties. The respondents seek the reconveyance of the property based on their co-ownership rights.
Jurisdictional Dispute
Lolita Copioso, along with the Doria spouses, moved to dismiss the complaint, arguing that the Municipal Trial Court (MTC) had jurisdiction due to the assessed value of the property being under P20,000. The trial court denied their motions, asserting that the nature of the action extends beyond mere assessments and could not be confined to a pecuniary valuation. Following the denial, Lolita filed a petition for certiorari with the Court of Appeals, which upheld the RTC’s jurisdiction.
Legal Framework
Petitioner relies on Section 33(3) of B.P. Blg. 129, amended by Section 3 of Republic Act No. 7691, which delineates the jurisdiction of Metropolitan, Municipal, and Municipal Circuit Trial Courts in civil actions with assessed values not exceeding P20,000. In contrast, the respondents argue that the case falls within the RTC's jurisdiction under Section 19(1) of the same law, which gives the RTC exclusive jurisdiction over actions incapable of pecuniary estimation.
Analysis of Jurisdiction
The Supreme Court analyzed whether the characteristics of the complaint for reconveyance, which included claims for annulment of sales and damages, fell under the jurisdiction of the RTC or the MTC. It was established that while the assessed value might suggest MTC jurisdiction, the underlying issues of title, ownership, and claims for damages highlighted the complexity of the case, necessitating the RTC's intervention.
Nature of the Action
The action filed by the respondents encompasses multiple causes, such as the annulment of sales, reconveyance, and claims for damages, which are inherently incapable of being valued mone
...continue readingCase Syllabus (G.R. No. 149243)
Case Overview
- The case concerns a petition for review filed by Lolita B. Copioso challenging the Decision of the Court of Appeals which dismissed her petition for certiorari regarding a complaint for reconveyance of two parcels of coconut land.
- The respondents, who are relatives of the petitioner, alleged that they were co-owners of the property which had been fraudulently transferred to the name of their deceased brother and others.
Parties Involved
- Petitioner: Lolita B. Copioso.
- Respondents: Lauro, Dolores, Rafael, Esteban, and Corazon Copioso, and the Court of Appeals.
- Other Involved Parties: Spouses Bernabe and Imelda Doria, and the estate of deceased Antonio Copioso, along with various vendees.
Background of the Case
- On July 4, 2000, the respondents filed a complaint for reconveyance alleging co-ownership of the property inherited from their parents.
- They claimed fraud and machination led to the property being transferred to Antonio Copioso and the Doria spouses, who later sold the property to third parties.
- The respondents sought reconveyance, asserting their rights as co-owners.
Legal Proceedings
- The respondents claimed the assessed value of the property was P3,770.00.
- Petitioner and the Doria spouses filed motions to dismiss based on jurisdic