SPS. BENITO DE BELEN AND MAXIMINA DE BELEN, PLAINTIFFS-APPELLANTS, VS. SPS. CRISANTO MARZO AND NORMA DE BELEN MARZO, DEFENDANTS-APPELLEES.

De Belen versus Marzo

The Case

This is a dispute within a family over a parcel of land in Batangas. Spouses Benito de Belen and Maximina de Belen, the parents, sued their daughter Norma de Belen Marzo and her husband Crisanto Marzo. The parents asked the court to cancel the transfer certificate of title and the tax declaration in the names of the spouses Marzo and to reconvey the land back to them. They claimed that their daughter, through fraud, made her father sign what he thought was a document to convert the land into a residential lot, when in truth it was a conveyance. The case matters for the bar because it is a clean illustration of how jurisdiction is determined: by the allegations in the complaint and the principal relief sought, in the light of the law that apportions jurisdiction among the courts. It also reminds us that an action for reconveyance or cancellation of title is an action involving title to real property, and so is capable of pecuniary estimation.

Procedural History

The parents filed their complaint for cancellation of title and assessment and for reconveyance with the Regional Trial Court of Balayan, Batangas, Branch 10, where it was docketed as a civil case. In a decision dated May 27, 2013, the Regional Trial Court dismissed the complaint for lack of jurisdiction. It reasoned that since the main objective of the parents was the recovery of ownership of the lot, which had an assessed value of 2,890 pesos, the case fell within the original jurisdiction of the Municipal Trial Court. It added that, even assuming it had jurisdiction, the parents failed to prove that the spouses Marzo had registered the lot in their names through fraud. The parents then brought the matter to the Supreme Court by appeal, assigning as errors the trial court's ruling that the action was capable of pecuniary estimation and its failure to rule that the contract was not valid. The Supreme Court denied the appeal and affirmed the decision of the Regional Trial Court.

Facts

On April 21, 1982, Benito de Belen was awarded a free patent over a parcel of land, covered by an original certificate of title. According to the parents, Norma de Belen Marzo at first convinced her father that she would apply for the reclassification of the property into a residential lot. Without their knowledge, however, Norma caused the lot to be subdivided into four parcels, one of which was covered by a transfer certificate of title in the name of Benito de Belen.

Sometime in 2005, the parents discovered that this title had been cancelled by another transfer certificate of title, this one registered in the names of the spouses Marzo. The Register of Deeds of Nasugbu, Batangas issued a certification that the documents of transfer from the title in the name of Benito de Belen to the title in the names of the spouses Marzo were not among the records available on file in its office. The parents said they did not remember having executed any document conveying the lot to the spouses Marzo.

The spouses Marzo countered that Norma had not convinced her father to apply for reclassification, and that she had no part in the subdivision. They said they had purchased the lot from the parents for valuable consideration on October 13, 1999, and that it was agreed their father would handle the preparation of the deed of sale and the other documents for the transfer and registration of the title in their names. Upon full payment, title was delivered and registered in their names. They had been in possession for seven years, and the parents had remained silent until they filed the complaint in 2006. They claimed to be purchasers in good faith and for value, and argued that their title, registered since October 22, 1999, had already become indefeasible and imprescriptible.

Issues

• Whether or not the Regional Trial Court had jurisdiction over the action, or whether jurisdiction belonged to the Municipal Trial Court because the action involved title to real property with an assessed value of 2,890 pesos.
• Whether or not the action was incapable of pecuniary estimation, such that it fell within the exclusive jurisdiction of the Regional Trial Court.

Applicable Provisions

Section 33 of Batas Pambansa 129, as amended, on the jurisdiction of the Metropolitan Trial Courts, Municipal Trial Courts and Municipal Circuit Trial Courts in civil cases, provides:

Section 33. Jurisdiction of Metropolitan Trial Courts, Municipal Trial Courts and Municipal Circuit Trial Courts in Civil Cases — Metropolitan Trial Courts, Municipal Trial Courts and Municipal Circuit Trial Courts shall exercise: x x x x (3) Exclusive original jurisdiction in all civil actions which involve title to, or possession of, real property, or any interest therein where the assessed value of the property or interest therein does not exceed Twenty thousand pesos (P20,000.00) or, in civil actions in Metro Manila, where such assessed value does not exceed Fifty thousand pesos (P50,000.00) x x x.

This provision bears directly on the case because the assessed value of the lot is 2,890 pesos, which does not exceed 20,000 pesos, so jurisdiction lies with the first level court and not with the Regional Trial Court.

Ruling

On the first issue, the Court held that jurisdiction over the subject matter is determined by the plaintiff's allegations in the complaint and the principal relief he seeks, in the light of the law that apportions the jurisdiction of courts. The parents claimed ownership because they never transferred the lot to the spouses Marzo, and they asked for annulment and cancellation of contracts and for reconveyance. The Court explained that an action involving title to real property means that the plaintiff's cause of action is based on a claim that he owns the property or has the legal right to have exclusive control, possession, enjoyment, or disposition of it. Title is the legal link between the person who owns the property and the property itself. Actions for reconveyance of, or for cancellation of title to, or to quiet title over real property fall under the classification of cases that involve title to, or possession of, real property, or any interest therein.

On the second issue, the Court held that the action was capable of pecuniary estimation. Under Section 19 of Batas Pambansa 129, as amended, the power of the Regional Trial Court to hear actions involving title to, or possession of, real property or any interest in it covers only real properties with an assessed value in excess of 20,000 pesos. The Regional Trial Court retained the exclusive power to hear actions the subject matter of which is not capable of pecuniary estimation. But under Section 33, if the assessed value of the real property outside Metro Manila involved in the suit is 20,000 pesos and below, jurisdiction lies in the first level courts. Since the assessed value of the lot, as shown by the tax declaration, is 2,890 pesos, jurisdiction over the case belongs not to the Regional Trial Court but to the Municipal Trial Court. With this conclusion, the Court found it unnecessary to pass upon the other issue raised in the appeal.

Doctrine

Jurisdiction over the subject matter of an action is determined by the allegations in the complaint and the principal relief sought, in the light of the law that apportions jurisdiction. An action for reconveyance of, or for cancellation of title to, or to quiet title over real property is an action involving title to, or possession of, real property, or any interest therein, and is therefore capable of pecuniary estimation. Where the assessed value of the real property outside Metro Manila does not exceed 20,000 pesos, exclusive original jurisdiction lies with the Municipal Trial Court under Section 33 of Batas Pambansa 129, as amended, and not with the Regional Trial Court. The Regional Trial Court's jurisdiction over actions involving title to real property covers only properties with an assessed value in excess of 20,000 pesos, although it retains exclusive power over actions the subject matter of which is not capable of pecuniary estimation.

Disposition

The Supreme Court denied the appeal and affirmed the decision of the Regional Trial Court of Balayan, Batangas, Branch 10, dismissing the complaint for lack of jurisdiction.

Remember This

The single line to memorize: an action for reconveyance or cancellation of title is an action involving title to real property, so jurisdiction depends on the assessed value, and where that value does not exceed 20,000 pesos outside Metro Manila, it is the Municipal Trial Court, not the Regional Trial Court, that has jurisdiction. Examiners like to use this case to test the distinction between actions capable and incapable of pecuniary estimation, and the rule that jurisdiction is fixed by the allegations of the complaint and the principal relief sought.