Heirs of Calixto Mejia VS Spouses Eugenio Geronimo

[ G.R. No.
207313, June 06, 2019 ]

HEIRS OF CALIXTO MEJIA, REP. BY THEIR
ATTORNEY-IN-FACT, MARCELA MEJIA-DELA CRUZ, PETITIONERS, V. SPOUSES EUGENIO
GERONIMO AND FLORIDA JOSE, RESPONDENTS
FACTS:
 The present petition originated from a complaint filed by the petitioners for "Declaration
of Nullity of Deed of Absolute Sale of Real Estate”, and incidentally, the recovery of
ownership and possession of the subject property.
 By way of affirmative defense, herein respondents argued that the RTC has NO
jurisdiction over the subject matter because (1) the petitioners sought to obtain title over
the subject property; and (2) the assessed value of the property was not within the
jurisdictional limit for RTCs
 the RTC dismissed the complaint for lack of jurisdiction and ruled that the case was
in the nature of an action for the recovery of ownership and possession of real property;
and that based on the present law, the RTC has no jurisdiction over the subject matter
because the assessed value of the subject property (pegged at P10,070.00), was below
the jurisdictional limit provided by law
 The petitioners directly filed the present petition for review with this Court in order to
raise the sole issue of jurisdiction, viz.: THE COURT A QUO COMMITTED SERIOUS
REVERSIBLE ERROR ON A QUESTION OF LAW WHEN IT DISMISSED THE
COMPLAINT ALLEGEDLY FOR LACK OF JURISDICTION, WHEN IT HAS, AS THE
CASE IS NOT ESSENTIALLY FOR SUM OF MONEY NOR QUESTION OF TITLE,
POSSESSION OR INTEREST THEREIN, BUT INVOLVES THE PRINCIPAL ISSUE OF
AUTHENTICITY OR GENUINENESS INCLUDING THE ISSUE OF NULLITY,
INVALIDITY OR VALIDITY OF THE DOCUMENTS. HENCE, INCAPABLE OF
PECUNIARY ESTIMATION.
ISSUE: WON the court a quo committed serious reversible error on a question of law when it
dismissed the complaint allegedly for lack of jurisdiction.
HELD:
The petitioners maintained that they principally sought for the annulment of the deed of sale
before the RTC; that the recovery of ownership and possession of the subject property were
merely incidental and ancillary reliefs; and that the subject matter of their complaint was
incapable of pecuniary estimation.
It is settled that where the basic issue is something other than the right to recover a sum of
money, where the money claim is purely incidental to, or a consequence of, the principal relief
sought, such actions are cases where the subject of the litigation may not be estimated in terms
of money, and therefore cognizable by the courts of first instance (now Regional Trial Courts).
[11] In Russell v. Vestil, [12] We declared an action for the annulment of a deed of sale or
conveyance as one incapable of pecuniary estimation and therefore within the jurisdiction of the
RTC
We have reviewed the complaint filed by the petitioners and so hold that what the petitioners
principally sought before the RTC was to nullify the Deed of Absolute Sale of Real Estate
Mortgage. The recovery of the petitioners' interest in the subject property simply became a
necessary consequence should the said deed be nullified. In the alternative, the petitioners
prayed that the deed of absolute sale be declared as an equitable mortgage and to allow the
legal redemption of the subject property. Considering that these reliefs were incapable of
pecuniary estimation, the RTC should have exercised jurisdiction over the petitioners' complaint.
Also, under Section 5(c), Rule 2 of the Rules of Court, where the causes of action are between
the same parties but pertain to different venues or jurisdictions, the joinder of causes of
action may be allowed in the RTC, provided that one of the causes of action falls within the
jurisdiction of said court and the venue lies therein.
Notable that the petitioners' complaint sought for the annulment of the deed of sale, and
incidentally, the recovery of ownership and possession of the subject property. Such complaint
had joined causes of action, which under existing rules, may be heard by the RTC since it has
jurisdiction to settle matters involving nullity of the deed of sale. Accordingly, the RTC erred in
issuing the assailed orders on the ground of lack of jurisdiction.

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[ G.R. No.

207313, June 06, 2019 ]

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