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HEIRS OF CONCHA v. LUMOCSO

FACTS:

The case involves a dispute over three parcels of land in Cogon, Dipolog City. The petitioners claim to be the rightful owners of the lots under Section 48(b) of the Public Land Act. They filed separate complaints for reconveyance and annulment of title with damages against the respondents, who are the patent holders and registered owners of the lots. The cases were filed in the RTC of Dipolog City.

The plaintiffs alleged that their parents acquired a 24-hectare parcel of land by homestead and had continuously possessed and occupied an additional 4 hectares within the property. They accused the defendants of forcibly entering and cutting trees in the premises. The plaintiffs claimed that they have acquired imperfect title to the land and that the defendants' free patent applications and titles were the result of fraud, deceit, bad faith, and misrepresentation.

The defendants filed motions to dismiss the complaints on various grounds, but the trial court denied them. The defendants then filed a petition with the CA, which reversed the trial court's resolutions and order, holding that the complaints were barred by the statute of limitations. The plaintiffs appealed the CA's decision.

ISSUES:

  1. Whether or not the Court of Appeals erred in dismissing the complaints on the ground of prescription.

  2. Whether the Regional Trial Court (RTC) or Municipal Trial Court (MTC) has jurisdiction over the cases.

  3. Whether the cases fall under the classification of cases that involve "title to, or possession of, real property, or any interest therein."

  4. Whether the issue of whether petitioner violated the provisions of the Master Deed and Declaration of Restriction of the Corporation is one that is incapable of pecuniary estimation.

  5. Whether the assessed value of the realty involved is the sole determinant of jurisdiction.

RULING:

  1. The Court held that the complaints involve actions for reconveyance and, as such, are subject to the ten-year prescriptive period. The Court ruled that the complaints must be dismissed as they involve titles issued for at least twenty-two years prior to the filing of the complaints.

  2. The MTC has jurisdiction over the cases because the assessed values of the subject lots are less than P20,000. The MTC has exclusive original jurisdiction over civil actions involving the title to, or possession of, real property, or any interest therein, where the assessed value of the property involved does not exceed P20,000.

  3. The cases fall under the classification of cases that involve "title to, or possession of, real property, or any interest therein." Actions for reconveyance of or for cancellation of title to or to quiet title over real property are considered cases that involve "title to, or possession of, real property, or any interest therein."

  4. Yes, the issue of whether petitioner violated the provisions of the Master Deed and Declaration of Restriction of the Corporation is one that is incapable of pecuniary estimation.

  5. Yes, the assessed value of the realty involved is the sole determinant of jurisdiction.

PRINCIPLES:

  • An action for reconveyance seeks the transfer of property wrongfully or erroneously registered to its rightful and legal owners. It is enough that the aggrieved 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 value.

  • An action for reconveyance based on fraud prescribes in ten years.

  • Jurisdiction over the subject matter is the power to hear and determine cases of the general class to which the proceedings in question belong. It is conferred by law and an objection based on this ground cannot be waived by the parties.

  • Under Section 19(2) of B.P. 129, MTCs have exclusive original jurisdiction over civil actions involving the title to, or possession of, real property, or any interest therein, where the assessed value of the property involved does not exceed P20,000.

  • 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."

  • The criterion for determining whether an action is one that is incapable of pecuniary estimation.

  • The determination of jurisdiction based on the assessed value of the realty involved.