Case Summary (G.R. No. 119347)
Petitioners
They claim ownership as co-heirs of the spouses Tautho and seek to annul a June 6, 1990 “Declaration of Heirs and Deed of Confirmation of a Previous Oral Agreement of Partition” that excluded them, and to compel partition among all heirs.
Respondents
Private respondents executed the June 6, 1990 deed, secured tax declarations for their shares, and moved for dismissal on jurisdictional grounds. Judge Vestil ruled that the assessed value (₱5,000) placed the case within the exclusive original jurisdiction of the Municipal Circuit Trial Court of Liloan, Compostela.
Key Dates
– September 28, 1994: Complaint filed in RTC Mandaue City (Civil Case No. MAN-2275)
– November 24, 1994: Motion to dismiss for lack of jurisdiction
– January 12, 1995: RTC order granting dismissal
– January 30, 1995: Petitioners’ motion for reconsideration
– February 13, 1995: RTC order denying reconsideration
– March 17, 1999: Supreme Court decision
Applicable Law
– 1987 Philippine Constitution (judicial power)
– Batas Pambansa Blg. 129, as amended by R.A. No. 7691
• Section 19(1): RTC has exclusive original jurisdiction over civil actions incapable of pecuniary estimation
• Section 33(3): MTC/MCTC has exclusive original jurisdiction over actions involving real property not exceeding assessed value thresholds
Facts
- Spouses Casimero and Cesaria Tautho died, leaving Lot 6149 to seven children; petitioners are their descendants and legal heirs.
- The land remained undivided until petitioners discovered the June 6, 1990 deed in which private respondents purportedly partitioned the property among themselves, excluding petitioners.
- Petitioners allege that the deed is false, perjurious, and void, as no oral partition occurred and they are rightful co-heirs.
Procedural History
Private respondents moved to dismiss on the basis that the assessed value (₱5,000) placed the action within the MCTC’s exclusive jurisdiction. RTC Branch 56 granted the motion and dismissed the complaint, then denied reconsideration. Petitioners filed a petition for certiorari with the Supreme Court.
Issue
Does the RTC possess jurisdiction over a complaint primarily seeking annulment of a false heirship and partition deed, when the assessed value of the property falls below the municipal courts’ threshold?
Ruling
The Supreme Court held that the complaint’s principal relief is the annulment of a public document, an action incapable of pecuniary estimation and therefore within the exclusive jurisdiction of the RTC under Section 19(1) of B.P. 129 (as amended). The incidental prayer for partition does not convert the action into one of recovery of real prope
Case Syllabus (G.R. No. 119347)
Facts of the Case
- Petitioners and private respondents are all descendants and legal heirs of the late spouses Casimero Tautho and Cesaria Tautho.
- The spouses owned in fee simple a parcel of land designated as Lot 6149, Cotcot, Liloan, Cebu, containing 56,977.40 sq. m., with an assessed value of ₱5,000.00.
- The property remained undivided among the heirs for years.
- On June 6, 1990, private respondents executed a public document entitled “Declaration of Heirs and Deed of Confirmation of a Previous Oral Agreement of Partition,” by which they purportedly divided the land among themselves, excluding petitioners.
- Petitioners discovered this document and alleged it to be false and perjurious because no oral partition occurred and petitioners were equally entitled as heirs.
- The complaint prayed for:
• Declaration that the June 6, 1990 document is null and void;
• Partition of the land into seven equal parts among all heirs (and their descendants);
• Attorney’s fees of ₱30,000.00.
Procedural Posture
- September 28, 1994: Petitioners filed Civil Case No. MAN-2275 (“Declaration of Nullity and Partition”) before RTC, Branch 56, Mandaue City.
- November 24, 1994: Private respondents moved to dismiss for lack of jurisdiction, citing Sec. 33(3) of B.P. 129 (as amended by R.A. 7691)—the assessed value (₱5,000.00) places the case within the exclusive original jurisdiction of the Municipal Circuit Trial Court of Liloan.
- Petitioners opposed, arguing the action is incapable of pecuniary estimat