6. SAN PEDRO v.

ASDALA
593 SCRA 397
JULY 22,2007
JURISDICTION OVER CASES THE SUBJECT MATTER OF WHICH INVOLVES
"TITLE TO, POSSESSION OF, REAL PROPERTY OR ANY INTEREST THEREIN"
UNDER SECTION 19(2) OF B.P. 129 IS DIVIDED BETWEEN THE FIRST AND
SECOND LEVEL COURTS, WITH THE ASSESSED VALUE OF THE REAL
PROPERTY INVOLVED AS THE BENCHMARK.
FACTS: Sometime in July 2001, private respondents Allan and Eleonor Dionisio (heirs
of spouses Apolonio and Valeriana Dionisio) filed with the MeTC of Quezon City a
Complaint against herein petitioners (Ana de guia San Pedro and Alejo Dopeo) and
Wood Crest Residents Association, Inc., for Accion Reivindicatoria, Quieting of Title and
Damages, with Prayer for Preliminary Mandatory Injunction.
PRs alleged that subject property located in Batasan Hills, Quezon City, with an
assessed value of P32,100.00, was titled in the name of SPS Dionisio but petitioners,
with malice and evident bad faith, claimed that they were the owners of a parcel of land
that encompasses and covers subject property but it was alleged in the complaint that
petitioners' TCT over the property was spurious. Since PRS had allegedly been
prevented from entering, possessing and using subject property they prayed that they
be declared the sole and absolute owners of the subject property. to recover
possession of the same and for payment of actual and moral damages, and attorney's
fees.
Petitioners filed a Motion to Dismiss on the ground that the MeTC had no jurisdiction
over the subject matter of the action, as the subject of litigation was incapable of
pecuniary estimation.
MeTC: denied the motion to dismiss under B.P129, as amended, the MeTC had
exclusive original jurisdiction over actions involving title to or possession of real property
of small value. Petitioners' Motion for Reconsideration was denied.
RTC (petition for certiorari): dismissed the petition and sustained the MeTC ruling
pursuant Section 33(3) of R.A. No. 7691, amending B.P. Blg. 129, the MeTC had
jurisdiction over the complaint as it involves recovery of ownership and possession
of real property located in QC, with an assessed value not exceeding P50,000.00.
MR was denied.
CA (petition for certiorari): dismissed the petition outright, holding that petitioners' should
have availed themselves of the remedy of appeal. Petitioners' MR was denied. Hence,
the petition for certiorari under rule 65.
ISSUES: WON the MeTC has jurisdiction over the case?
RULING: YES. The Court reiterates the ruling in Heirs of Valeriano S. Concha, Sr. v.
Spouses Lumocso,to wit: In a number of cases, we have held that actions for
reconveyance of or for cancellation of title to or to quiet title over real property are
actions that fall under the classification of cases that involve title to, or possession of,
real property, or any interest therein. x x x x Thus, under the old law, there was no

substantial effect on jurisdiction whether a case is one, the subject matter of which was
incapable of pecuniary estimation, under Section 19(1) of B.P. 129, or one involving title
to property under Section 19(2). The distinction between the two classes became
crucial with the amendment introduced by R.A. No. 7691 in 1994, which expanded the
exclusive original jurisdiction of the first level courts to include "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) exclusive of interest, damages of
whatever kind, attorney's fees, litigation expenses and costs."
Thus, under the present law, original jurisdiction over cases the subject matter of which
involves "title to, possession of, real property or any interest therein" under Section
19(2) of B.P. 129 is divided between the first and second level courts, with the assessed
value of the real property involved as the benchmark. This amendment was introduced
to "unclog the overloaded dockets of the RTCs which would result in the speedier
administration of justice."
Clearly, the RTC and the CA ruled correctly that the MeTC had jurisdiction over private
respondents' complaint for Accion Reivindicatoria involving a lot in QC with an assessed
value not exceeding P50,000.
#BERCENIO

7. BANK OF COMMERCE vs. SPS. NATIVIDAD and PRUDENCIO SAN PABLO, JR.
522 SCRA 713
APRIL 27,2007
AN ACTION FOR QUIETING OF TITLE, A REAL ACTION, THE JURISDICTION OVER
WHICH IS DETERMINED BY THE ASSESSED VALUE OF THE PROPERTY.
FACTS: ON 20 DECEMBER 1994, MELENCio Santos obtained a P1,064,000.40 loan
from Direct Funders Management and Consultancy Inc., and as security for Natividad
executed a SPA authorizing the Santos to mortgage a paraphernal real property
registered under her name and covered by TCT No. 26469-756. Upon learning that
Santos debt with Direct Funders had been fully settled, the spouses then demanded
from Santos to turn over to them the TCT of the subject property but the latter failed to
do so despite repeated demands. Thus, the spouses inquired the status of the TCT of
the subject property with the Register of Deeds of Mandaue City and to their surprise,
they discovered that the property was again used by Santos as collateral for another
loan obligation he secured from the Bank of Commerce. As shown in the annotation
stamped at the back of the title, the spouses purportedly authorized Santos to mortgage
the subject property to the Bank of Commerce, as evidenced by the SPA allegedly
signed by Natividad on 29 March 1995 and that the spouses signed a Deed of Real
Estate Mortgage over the subject property in favor of Bank of Commerce, which they
never did.
The spouses San Pablo filed a Complaint seeking for the Quieting of Title and
Nullification of the SPA and the deed of real estate mortgage with the prayer for
damages against Santos and the Bank of Commerce before the MTC of Mandaue City.
The spouses claimed that their signatures on the SPA and the Deed of Real Estate
Mortgage allegedly executed to secure a loan with the Bank of Commerce were forged
and that they never authorized the subsequent loan obligation with the Bank of
Commerce.
During the pendency of the case, the Bank of Commerce, for non-payment of the loan,
initiated the foreclosure proceedings and acquired the property in the auction sale thus
a Certificate of Sale was issued under its name. Accordingly, the spouses amended
their complaint to include the prayer for annulment of the foreclosure sale.
MTC: dismissed the complaint for lack of merit and declared that while it was proven
that the signatures of the spouses San Pablo on the loan documents were forged, the
Bank of Commerce was nevertheless in good faith.
RTC: Upon appeal, the RTC affirmed the ruling of the MTC. Motion for reconsideration
filed by the Spouses San Pablo was denied.
CA (petition for review under rule 42): the appellate court reversed the decisions of the
lower courts and ruled that since it was duly proven that the signatures of the spouses
San Pablo on the loan documents were forged, then such spurious documents could
never become a valid source of title. The mortgage contract executed by Santos over

the subject property in favor of Bank of Commerce, without the authority of the spouses
San Pablo, was therefore unenforceable, unless ratified. Hece, the petition for review on
certiorari under rule 45.
ISSUES: WON MTC has jurisdiction over the case?
RULING: YES. The mortgage of the subject property to the Bank of Commerce,
annotated on the Spouses San Pablos TCT, constitutes a cloud on their title to the
subject property, which may, at first, appear valid and effective, but is allegedly invalid or
voidable for having been made without their knowledge and authority as registered
owners. It is established that the case filed by the spouses San Pablo before the MTC is
actually an action for quieting of title, a real action, the jurisdiction over which is
determined by the assessed value of the property. The assessed value of the subject
property located in Mandaue City, as alleged in the complaint, is P4,900.00, which aptly
falls within the jurisdiction of the MTC.
According to Section 33 of Batas Pambansa Blg. 129, as amended, otherwise known as
The Judiciary Reorganization Act of 1980: Sec. 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 (P50,000.0) exclusive of interest, damages of whatever kind, attorneys
fees litigation expenses and costs: Provided, That in cases of land not declared for
taxation purposes, the value of such property shall be determined by the assessed
value of the adjacent lots. (As amended, R.A. No. 7691.)
#BERCENIO