Actions Incapable of Pecuniary Estimation

Genesis Investment v. Heirs of Ebarasabal

Peralta, J.

FACTS
On November 12, 2003, herein respondents filed against herein petitioners filed in the
RTC a Complaint for Declaration of Nullity of Documents, Recovery of Shares,
Partition, Damages and Attorney’s Fees. Herein petitioners file a Motion to Dismiss
contending that the RTC has no jurisdiction to try the case on the ground that the case
involves title to or possession or real property or any interest therein and since the
assessed value of the subject property does not exceed P20,000.00 (the same being only
P11,900.00), the action falls within the jurisdiction of the MTC. RTC granted petitioners’
Motion to Dismiss. Respondents filed a Motion for Partial Reconsideration arguing that
their complaint consists of several causes of action, including one for annulment of
documents, which is incapable of pecuniary estimation and as such, falls within the
jurisdiction of the RTC. RTC granted the Motion for Partial Reconsideration and
reversed its earlier Order, finding to be with merit the contention of the movants that the
primary relief prayed for, which is the declaration of nullity of documents, is
unquestionably incapable of pecuniary estimation. Petitioners filed a Motion for
reconsideration which the RTC denied. Aggrieved, they filed a petition for certiorari with
the CA. However, the CA dismissed the petition holding that the subject matter of the
complaint is incapable of pecuniary estimation and therefore, within the jurisdiction of
the RTC. Hence, the instant petition for review on certiorari.

ISSUE
Whether or not the CA gravely erred in concluding that the RTC has jurisdiction over the
instant case when the allegations in the complain show that the main cause of action of
the respondents for the recovery of land which has an assessed value of P11,900.00 and
thus, within the jurisdiction of the MTC

RULING
No. The CA was correct in dismissing the petition.
It is true that one of the causes of action of the respondents pertains to the title,
possession and interest of each of the contending parties, the assessed value of which
falls within the jurisdiction of the MTC. However, a complete reading of the complaint
would really show that, based on the nature of the suit, the allegations therein, and the
reliefs prayed for, the action is within the jurisdiction of the RTC.
Clearly, this is a case of joinder of caused of action which comprehends more than the
issue of partition of or recovery of shares of interest over the real property in question but
includes an action for declaration of nullity of contracts and documents which is
incapable of pecuniary estimation.
In the instant case, the recovery of the undivided shares over the disputed lot, which were
included in the sale, simply becomes a necessary consequence if the above deed is
nullified. Hence, since the principal action sought is something other than the recovery of
a sum of money, the action is incapable of pecuniary estimation and thus, cognizable by
the RTC.
The petition is denied.
 Actions Incapable of Pecuniary Estimation
Heirs of Sebe v. Heirs of Sevilla
G.R. No. 174497
October 12, 2009

Abad, J.

FACTS
The Sebes had been the owner for over 40 years of two unregistered lots n San Jose,
Dipolog City, with a total assessed value of P9,910.00. In 1991, they constituted a real
estate mortgage over it in defendant Sevilla’s favor. The Sebes claimed that, through
fraud, defendant got them to sign documents conveying the lots to him. In his Answer,
Sevilla insisted that he bought the lots from the Sebes in a regular manner. Petitioners
alleged that defendant violated their right to ownership by tricking them into signing
documents of absolute sale, rather than just a real estate mortgage to secure a loan they
got from him.
Petitioners then filed with the RTC a complaint against defendants for Annulment of
Document, Reconveyance and Recovery of Possession of two lots. RTC dismissed the
case for lack of jurisdiction over the subject matter considering that the relief sought was
reconveyance of title and possession of lots that had a total value of less than P20,000.00.
Petitioners filed a Motion for Reconsideration, contending that it was a case of
annulment of documents and since such was incapable of pecuniary estimation, it
squarely fell within the jurisdiction of the RTC.

ISSUE
Whether or not petitioners’ action involving the two lots valued at less than P20,000 falls
within the jurisdiction of the RTC

RULING
Whether a court has jurisdiction over the subject matter of a particular action is
determined by the plaintiffs allegations in the complaint and the principal relief sought in
the light of the law that apportions the jurisdiction of courts. An action involving title to
real property means that the plaintiffs cause of action is based on a claim that he owns
such property. Thus, a plaintiff’s action for cancellation and of a certificate of title may
only be a necessary consequence of the defendant’s lack of title to real property. The
present controversy is which of them has valid title two the two lots.
The present action therefore is not about the declaration of nullity of documents covering
the lots in dispute. These would merely follow after the trial court shall have first
resolved the issue of which between the contending parties is the lawful owner of such
lots, jurisdiction over which is determined by the assessed value of such lots.
Petition is dismissed.
 Actions Incapable of Pecuniary Estimation
Spouses Pajares v. Remarkable Laundry
G.R. No. 212690
February 20, 2017

Del Castillo, J.

FACTS
Respondent filed a Complaint on Breach of Contract and Damages against herein
petitioners before the RTC of Cebu. Respondent alleged that it entered into a Remarkable
Dealer Outlet Contract with petitioners whereby the latter acted as a dealer outlet and
that petitioners violated a certain article of said contract, which required them to produce
at least 200 kilos of laundry each week. They also ceased operations on account of lack
of personnel. Respondent made written demands upon petitioners for the payment of
penalties imposed and provided for in the contract, but the latter failed to pay. They
prayed that the said defendant be ordered to pay incidental and consequential damages
amounting to P280,000.00.
The RTC issued an order dismissing the case for lack of jurisdiction, stating that the
complaint is for the recovery of damages for the alleged breach of contract. Respondent
filed its Motion for Reconsideration arguing that as said case is for breach of contract, or
one whose subject is incapable of pecuniary estimation, jurisdiction thus falls with the
RTC. On petition for certiorari filed by respondents seeking to nullify the RTC’s orders,
the CA set aside the first order of the RTC and remanding the case to the court a quo for
further proceedings, stating that such complaint is one incapable of pecuniary estimation.
Petitioners sought to reconsider, but were denied. Hence, the present petition.

ISSUE
Whether or not the CA erred in declaring that the RTC had jurisdiction over the
respondent’s complaint which, although denominated as breach of contract, is essentially
one for simple payment of damages

RULING
Yes, the CA erred in declaring that the RTC had jurisdiction over the case.
In ruling that the complaint is one incapable of pecuniary estimation, the CA based such
on the fact that a case for breach of contract is a cause of action either for specific
performance or rescission of contracts, which is incapable of pecuniary estimation.
However, they were not able to determine whether, from the complaint, respondent
actually intended to initiate an action for specific performance or an action for rescission
of contract.
After reviewing the complaint, an analysis of the factual and material allegations in the
complaint shows that there is nothing therein which would support a conclusion that
respondent’s complaint is one for specific performance. They just merely prayed for the
payment of the incidental and consequential damages.
Breach of contract may also be the cause of action in a complaint for damages. Thus, it is
not correct to immediately conclude, as the CA erroneously did, that since the cause of
action is breach of contract, the case would only either be specific performance or
rescission of contract because it may happen, as in this case, that the complaint is one for
damages.
Since the total amount of damages claimed by respondent with the RTC amounted only
to P280,000.00.00, said court was correct in refusing to take cognizance of the case.
 Actions Incapable of Pecuniary Estimation
G.R. No. 20832
March 10, 2014

Velasco, Jr.

FACTS
Alfredo R. Bautista, petitioner’s predecessor, inherited a free-patent land in Poblacion,
Lupon, Davao. A few years later, he subdivided the property and solid it to several
vendees, herein respondents, via notarized deed of absolute sale. Three years after the
said sale, Bautista filed a complaint for repurchase against respondents before the RTC,
anchoring his cause of action on Section 119 of Commonwealth Act No. 141, which
allows repurchase of every conveyance of land acquired under free patent, within a
period of five years. Respondents, in their Answer, raised lack of cause of action,
estoppel, prescription and laches as defenses. Respondents entered into a compromise
agreement with petitioners, whereby they agreed to cede to petitioners a portion of the
property as well as to waive all claims and counterclaims against each other. However,
other respondents filed a Motion to Dismiss alleging that the complaint failed to state the
value of the property to be recovered. They asserted that the total value of the property is
only P16,500, and therefore, RTC has no jurisdiction over the case. RTC issued the
assailed order dismissing the complaint for lack of jurisdiction. Petitioners argue that an
action for repurchase is not a real action, but one incapable of pecuniary estimation, it
being founded on privity of contract between the parties. According to them, what they
seek is the enforcement of their right to repurchase under Sec. 119 of CA No. 141.

ISSUE
Whether or not the action filed by petitioners is one involving title to or possession of
real property or any interest therein or one incapable of pecuniary estimation.

RULING
Yes, the Court rules that the complaint to redeem a land subject of a free patent is a civil
action incapable of pecuniary estimation.
It is a well-settled rule that jurisdiction of the court is determined by the allegations in the
complaint and the character of the relief sought. If it is primarily for the recovery of a
sum of money, the claim is considered capable of pecuniary estimation. But where the
basic issue is something other than the right to recover a sum of money, where the
money claim is purely incidental thereto, such actions are incapable of pecuniary
estimation. The Court finds that the instant case is one for specific performance. THhe
facts are clear that the lots were covered by a free patent. And as it is allowed in Sec. 119
of CA No. 141, it is basic that the law is deemed written into every contract.
Moreover, respondents can no longer question the jurisdiction of the RTC as they have
already fully participated in the case.
Petition is granted.
 Actions Incapable of Pecuniary Estimation
Russel et. al v. Hon. Ventil et. al
G.R. No. 119347
March 17, 1999

Kapunan, J.

FACTS:
Petitioners filed a complaint against private respondents, denominated “Declaration of
Nullity and Partition,” with the RTC of Mandaue City. Petitioners are co-owners of the
subject land. It was previously owned by the spouses Tautho and upon their death. The
property was inherited by their legal heirs, herein petitioners and private respondents.
Since then, the lot had remained undivided until petitioners discovered a public
document denominated, “Declaration of Heirs and Deed of Confirmation of a Previous
Oral Agreement of Partition.” Private respondents divided the property among
themselves to the exclusion of petitioners who are also entitled to the said lot. The
complaint prayed that the document be declared null and void and an order be issued to
partition the land among all the heirs. Private respondents insist that the action is one for
re-partition and since the assessed value of the subject land is P5,000.00, the case falls
within the jurisdiction of the MTC. Petitioners maintain the view that the complaint filed
is one for the annulment of a document, which is clearly one incapable of pecuniary
estimation, thus, cognizable by the RTC. Respondents’ Motion to Dismiss was granted,
hence, this petition.

ISSUE
Whether or not the Regional Trial Court has jurisdiction to entertain the said civil case

RULING
Yes, RTC has jurisdiction on the case.
The complaint filed before the RTC is doubtless one incapable of pecuniary estimation.
While the complaint also prays for the partition of the property, this is just incidental to
the main action, which is the declaration of the nullity of the document above-described.
It is settled that jurisdiction over the subject matter of a case is conferred by law and is
determined by the allegations in the complaint and the character of the relief sought,
irrespective or whether the plaintiff is entitled to all or some of the claims asserted
therein. Here, the subject matter is annulment of a document denominated as
“Declaration of Heirs and Deed of Confirmation of Previous Oral Partition.” The main
purpose of petitioners in filing the complaint is to declare null and void the document in
which private respondents declared themselves as the only heirs.
Petition is granted.