Case Summary (G.R. No. 198402)
Petitioner
Heirs of Generoso Sebe, Aurelia Censero Sebe, and Lydia Sebe, seeking annulment of conveyance documents, reconveyance of title, recovery of possession, and damages.
Respondent
Heirs of Veronico Sevilla and the Technology and Livelihood Resource Center, claiming a valid purchase and subsequent mortgage of the same lots.
Key Dates
– June 3, 1991: Alleged execution of “quitclaim” affidavits by the Sebes.
– September 23, 1991: Issuance of Torrens titles in favor of Sevilla.
– August 10, 1999: Filing of the original complaint in the Regional Trial Court (RTC), Dipolog City, Branch 9.
– November 25, 1999: Amendment of complaint to address a deed of confirmation of sale.
– August 8, 2006: RTC dismissal for lack of jurisdiction.
– August 31, 2006: Denial of motion for reconsideration.
– October 12, 2009: Supreme Court decision.
Applicable Law
– 1987 Philippine Constitution, Article VIII, Section 6(1) on judicial power and court hierarchy.
– Judiciary Reorganization Act of 1980 (Batas Pambansa Blg. 129), as amended by Republic Act No. 7601:
• Section 19 grants RTC exclusive original jurisdiction over civil actions incapable of pecuniary estimation and those involving title to or possession of real property exceeding ₱20,000.00.
• Section 33 confers on Municipal Trial Courts exclusive original jurisdiction over civil actions involving title to or possession of real property with assessed value not exceeding ₱20,000.00.
Issue
Whether the Sebes’s action—seeking annulment of fraudulent conveyance documents, reconveyance of title, recovery of possession, and damages over real property assessed below ₱20,000.00—falls within the exclusive original jurisdiction of the RTC or of the Municipal Trial Court.
Facts
- The Sebes owned two unregistered lots in Dipolog City, assessed at ₱9,910.00.
- In 1991, Sevilla induced them—under the guise of a mortgage—to execute “quitclaim” affidavits that functioned as deeds of sale for ₱10,000.00.
- No notarial appearance by the Sebes occurred, yet Torrens titles issued in Sevilla’s name on September 23, 1991.
- Sevilla mortgaged the lots to the Technology and Livelihood Resource Center for ₱869,555.00 and later forced tenant occupants out, harvesting crops worth ₱20,000.00.
- Plaintiffs alleged forgery of subsequent deeds of confirmation of sale, seizure of possession by force, loss of earnings, and incurred attorney’s fees and litigation costs.
- They prayed for:
a. Annulment of the quitclaim affidavits and deeds of confirmation of sale;
b. Declaration as lawful owners;
c. Restoration of possession;
d. Recovery of lost produce, moral and exemplary damages, attorney’s fees, and litigation expenses.
Procedural History
The RTC dismissed the complaint for lack of jurisdiction, holding that actions involving title or possession of property under ₱20,000 fall under the jurisdiction of first-level courts. The Sebes argued that their suit was incapable of pecuniary estimation because it joined annulment of contracts, reconveyance, and damages—relying on precedents such as De Rivera v. Halili and Copioso v. Copioso. The RTC denied reconsideration, citing Spouses Huguete v. Spouses Embudo to reaffirm the threshold valuation test.
Ruling
The Supreme Court affirmed the RTC’s dismissal, holding that jurisdiction depends on the principal relief sought and the assessed value of the property. Since the Sebes ultimately seek to determine rightful ownership and recover possession of real property assessed at ₱9,910.00, their action is a real action governed by Section 33 of BP 129, as amended. Incidental damages do not affect the jurisdictional threshold.
Reasoni
Case Syllabus (G.R. No. 198402)
Procedural Posture
- Petitioners filed a petition for review on certiorari before the Supreme Court to reverse the RTC of Dipolog City, Branch 9 Order dated August 8, 2006 in Civil Case No. 5435.
- The RTC had dismissed the complaint for lack of jurisdiction over actions involving real property assessed below ₱20,000.00.
- Petitioners’ motion for reconsideration, filed on August 22, 2006, was denied on August 31, 2006.
- Respondents are the heirs of Veronico Sevilla and the Technology and Livelihood Resource Center, substituted after Sevilla’s death.
Facts
- On August 10, 1999, Generoso and Aurelia Sebe and their daughter Lydia filed before the RTC of Dipolog City a complaint for annulment of documents, reconveyance, recovery of possession, and damages.
- The subject consisted of two unregistered lots in Dampalan, San Jose, Dipolog City, with a combined assessed value of ₱9,910.00 (Tax Declaration No. 012-239).
- On November 25, 1999, the Sebes amended their complaint to address a deed of confirmation of sale disclosed in the defendant’s answer.
- The Sebes alleged that Sevilla induced them, by fraud and under false pretense of a real estate mortgage, to sign quitclaim affidavits and deeds conveying ownership for ₱10,000.00.
- Sevilla obtained Torrens titles on September 23, 1991, mortgaged the lots for ₱869,555.00 to the Technology and Livelihood Resource Center, and later caused deeds of confirmation of sale (forged signatures) on December 24, 1991.
- In 1992 Sevilla declared the lots under his name, seized possession by force, harvested crops worth ₱20,000.00, and refused to return the lots.
- The Sebes incurred attorney’s fees, litigation expenses, loss of earnings, and claimed moral and exemplary damages.
- Generoso Sebe died during the proceedings; his heirs substituted. Veronico Sevilla