HEIRS OF VALERIANO CONCHA vs. SPOUSES GREGORIO LUMOCSO
Facts:
Petitioners, heirs of spouses Dorotea and Valeriano Concha, Sr., claim to be the rightful owners of a 2 lots all situated in Cogon, Dipolog City, under Section 48b! of Commonwealth "ct "ct #o. #o. $4$ $4$ C." C.".. #o. #o. $4$! $4$!,, othe otherw rwis isee %now %nown n as the the Publ Public ic &and &and "ct. ct. 'esp 'espon onde dent nt siblings &umocso are the patent holders and registered owners of the sub(ect lots. )he *eirs of Valeriano Valeriano filed for a complaint for 'econ+eyance andor an dor "nnulment of )itle with Damages against respondents, see%ing to annul -ree Patent and the corresponding riginal Certificate of )itle issued in the name of /0regorio &umocso/ co+ering a certain parcel of land. 'espondents mo+ed for the dismissal of the respecti+e cases against them on the same grounds of1 a! lac% of (urisdiction of the ')C o+er the sub(ect matters of the complaints b! failure to state causes of action for recon+eyance c! prescription and d! wai+er, abandonment, laches and estoppel. n the issue of (urisdiction, respondents contended that the ')C has no (urisdiction o+er the complaints pursuant to Section $32! of o f atas Pambansa lg. .P.! .P.! $23, as amended by '.". #o. 563$, as in each case, the assessed assessed +alues of the sub(ect sub(ect lots are less than P27,777.77. P27,777.77. Petitioner Petitionerss opposed, contending contending that the instant instant cases in+ol+e actions actions the sub(ect sub(ect matters of which are incapable of pecuniary estimation which, under Section $3$! of .P. $23, as amended by '.". 563$, fall within the eclusi+e original (urisdiction of the ')Cs. )hey also contended that they ha+e two main causes of action1 for recon+eyance and for reco+ery of the +alue of the trees felled by respondents. *ence, the totality of the claims must be considered which, if computed, allegedly falls within the eclusi+e original (urisdiction of the ')C. ')C. )rial court D9#:9D the ;otion to Dismiss of the respondents. C" '9V9'S9D the resolutions and order of the trial court. :t held that e+en assuming that the complaints state a cause of action, the same ha+e been barred by the statute of limitations. -urthermore, an action for recon+eyance based on fraud prescribes in ten $7! years, hence, the instant complaints co mplaints must be dismissed as they in+ol+e titles issued for at least twenty
Issue:
># ')C has (urisdiction o+er the complaints herein pursuant to Section $32! of atas Pambansa lg. .P.! $23, as amended by '.". #o. 563$
Held: No. MTC has the ju!sd!ct!o" o#e the su$jected #alue.
?urisdiction o+er the sub(ect matter is the power to hear and determine cases of the general class to which the proceedings in @uestion belong. :t is conferred by law and an ob(ection based on this ground cannot be wai+ed by the parties. )o determine whether a court has (urisdiction o+er the sub(ect matter of a case, it is important to determine the nature of the cause of action and of the relief sought. )he trial court correctly held that the instant cases in+ol+e actions for recon+eyance. "n action for recon+eyance respects the decree of registration as incontro+ertible but see%s the transfer of property, which has been wrongfully or erroneously registered in other personsA names, to its rightful and legal owners, or to those who claim to ha+e a better right. )here is no special ground for an action for recon+eyance. :t is enough that the aggrie+ed party has a legal claim on the property superior to that of the registered owner and that the property has not yet passed to the hands of an innocent purchaser for +alue. eing in the nature of actions for recon+eyance or actions to remo+e cloud on oneAs title, the applicable law to determine which court has (urisdiction is Section $32! of .P. $23, as amended by '.". #o. 563$1 “Section 19. Jurisdiction in Civil Cases.-- Regional Trial Courts shall exercise exclusive original jurisdiction: (2 !n all civil actions "hich involve the title to# or $ossession o%# real $ro$ert&# or an& interest therein# "here the assessed value o% the $ro$ert& involved exceeds T"ent& thousand $esos ('2#. or %or civil actions in )etro )anila# "here such value exceeds *i%t& thousand $esos ('+#. exce$t actions %or %orci,le entr& into and unla"%ul detainer o% lands or ,uildings# original jurisdiction over "hich is con%erred u$on the )etro$olitan Trial Courts# )unici$al Trial Courts# and )unici$al Circuit Trial Courts :n the cases at bar, it is undisputed that the sub(ect lots are situated in Cogon, Dipolog City and their assessed +alues are less than P27,777.77. *ence, the ;)C clearly has (urisdiction. PetitionersA contention that this case is one that is incapable of pecuniary estimation under the eclusi+e original (urisdiction of the ')C pursuant to Section $3$! of .P. $23 is erroneous. :n a number of cases, SC ha+e held that actions for recon+eyance of or for cancellation of title to or to @uiet title o+er real property are actions that fall under the classification of cases that in+ol+e /title to, or possession of, real property, or any interest therein./
