### Facts:
On February 3, 2014, Petitioner Alona G. Roldan filed a foreclosure action against Respondents Spouses Clarence and Anna Lee T. Barrios and Romel D. Matorres. The dispute centered on a loan of P250,000 made by Roldan to the Barrioses, secured by a Deed of Real Estate Mortgage over a parcel of land. The Barrioses failed to repay the loan, and it was discovered they had subsequently mortgaged the property to Matorres. Roldan sought the foreclosure of the mortgage due to non-payment.
The Spouses Barrios argued the loan computation was inaccurate and motioned for suspension of the foreclosure, citing a pending petition for rehabilitation. Matorres filed his defense, recognizing the mortgage to him but denied any transaction with Roldan, initiating his foreclosure case against the Barrioses.
The RTC dismissed the foreclosure cases due to jurisdictional issues, determining that the assessed value of the property (P13,380.00) meant jurisdiction lay with a lower court. Roldan’s and Matorres’s motions for reconsideration were denied, prompting the filing of a petition for certiorari claiming the RTC has jurisdiction over foreclosure of mortgage as it is an action incapable of pecuniary estimation.
### Issues:
1. Whether the Regional Trial Court (RTC) committed grave abuse of discretion in dismissing the foreclosure cases for lack of jurisdiction.
2. Whether foreclosure of a mortgage is an action incapable of pecuniary estimation and thus falls within the exclusive jurisdiction of the RTC.
### Court’s Decision:
The Supreme Court dismissed the petition, affirming the RTC decision that jurisdiction over foreclosure cases is determined by the assessed value of the property involved. Since the value was below the threshold (P13,380.00), jurisdiction correctly belonged to the first-level courts, contrary to Roldan’s claim. The Court clarified the distinction between actions incapable of pecuniary estimation and those determined by the property’s assessed value, finding the latter applies in foreclosure of mortgage cases. The petition’s reliance on the Russell vs. Vestil case was deemed misplaced, as it pertains to actions distinctly different from a foreclosure case.
### Doctrine:
The Supreme Court reiterated the doctrine that jurisdiction over real action cases, such as foreclosure of real estate mortgage, is determined by the assessed value of the property involved. If the assessed value is below the jurisdictional limit of P20,000.00 (or P50,000.00 in Metro Manila), first-level courts have jurisdiction over the matter. The essence of foreclosure involves the judicial recognition of a property debt and the sale of the mortgaged property, classifying it as a real action case where the property’s value dictates jurisdiction.
### Class Notes:
1. **Jurisdiction over Foreclosure Cases:** Determined by the assessed value of the property. If below P20,000.00, jurisdiction lies with first-level courts (MTC, METC, MCTC).
2. **Action Incapable of Pecuniary Estimation:** Jurisdiction lies with the Regional Trial Courts, except when specific laws provide otherwise.
3. **Real Action Cases:** Involve direct interests over real property. The assessed value of the property dictates the appropriate court of jurisdiction.
4. **Key Statutes:**
– Batas Pambansa Blg. 129 as amended by Republic Act No. 7691 details the jurisdictional thresholds for courts.
– Section 19 and 33 of BP 129 delineate jurisdiction between RTCs and first-level courts based on property value and action type.
### Historical Background:
The jurisdictional rules and thresholds, as outlined in BP 129 as amended by RA 7691, reflect the legislative intent to allocate cases to judicial bodies appropriately equipped to handle them, considering the nature of the dispute and the value involved. The Roldan vs. Barrioses and Matorres case underscores the judiciary’s endeavor to assign cases based on clear legal criteria to ensure efficiency and fairness in the legal process.
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