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SURVIVING HEIRS OF ALFREDO R. BAUTISTA v. FRANCISCO LINDO

FACTS:

Alfredo R. Bautista inherited a free-patent land in 1983 and sold portions of it to several vendees through a notarized deed of absolute sale. Bautista then filed a complaint for repurchase against the vendees, invoking Section 119 of the Public Land Act. The vendees raised various defenses in their answer. Bautista died during the pendency of the case and was substituted by Epifania G. Bautista. Some of the vendees entered into a compromise agreement with the petitioners, while other vendees filed a Motion to Dismiss, alleging lack of jurisdiction over the complaint. The trial court granted the motion to dismiss, ruling that the complaint failed to state the value of the property sought to be recovered and that repurchase is a real action. The petitioners filed a motion for reconsideration, which was denied by the trial court. Hence, the petition for review before the Supreme Court.

ISSUES:

  1. Whether 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.

  2. Whether or not the Municipal Trial Court (MTC) or the Regional Trial Court (RTC) has jurisdiction over the case involving the reconveyance of the lots.

  3. Whether or not the respondents are barred from questioning the jurisdiction of the RTC.

RULING:

  1. The Supreme Court ruled that the action filed by the petitioners is one 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 the action is primarily for the recovery of a sum of money, it is considered capable of pecuniary estimation. But if the basic issue is something other than the right to recover a sum of money, and the money claim is purely incidental or a consequence of the principal relief sought, then the action is considered incapable of pecuniary estimation. In this case, the cause of action to redeem the land was found to be one for specific performance, which is incapable of pecuniary estimation. Therefore, the action is cognizable exclusively by the Regional Trial Courts (RTCs).

  2. The action for reconveyance of the lots is not solely dependent on the exercise of the right to repurchase, but rather it is incidental to the exercise of such right. Thus, the action is incapable of pecuniary estimation and the MTC does not have jurisdiction over the case. The RTC has jurisdiction over the case.

  3. The respondents are barred from questioning the jurisdiction of the RTC. By actively participating in the proceedings and invoking the authority of the RTC by asking for affirmative reliefs, they are deemed estopped from questioning the jurisdiction of the court.

PRINCIPLES:

  • Jurisdiction of courts is granted by the Constitution and pertinent laws.

  • Jurisdiction of RTCs is provided in Section 19 of BP 129, while jurisdiction of first level courts is prescribed in Section 33 of BP 129.

  • The nature of the principal action or remedy sought determines whether an action is capable of pecuniary estimation or not.

  • Actions for specific performance are considered incapable of pecuniary estimation.

  • The law is deemed written into every contract, and provisions of positive law that regulate contracts are deemed part of the contract.

  • The jurisdiction of the court is determined by the nature of the action or the subject matter of the controversy.

  • The jurisdiction of the court over a case may be questioned at the first opportunity, and a party who takes part in the proceedings before the court and actively defends his position without questioning the jurisdiction cannot later on claim lack of jurisdiction.

  • The principle of jurisdiction by estoppel applies when a party raises defenses, actively participates in the proceedings, and asks for affirmative reliefs from the court, thereby estopping him from questioning the jurisdiction of the court.