In Elmer Montero v. Santiago Montero, Jr. and Charlie Montero, the Supreme Court reiterated that the assessed value of a property determines which court has jurisdiction over disputes involving title or possession. The Court emphasized that if the assessed value is below a certain threshold, the case must be filed with the Metropolitan Trial Courts, Municipal Trial Courts, or Municipal Circuit Trial Courts, not the Regional Trial Court. This ruling clarifies the importance of accurately assessing property value to ensure cases are filed in the correct court, preventing delays and dismissals due to jurisdictional errors. This means individuals involved in property disputes must first ascertain the assessed value to avoid filing in the wrong court, which can lead to wasted time and resources.

Property Title Showdown: Who Decides Ownership When Values Are Low?

The case revolves around a parcel of land in Pilar, Abra, originally owned by Dominga Taeza. Elmer Montero, claiming to be an heir of Dominga, filed a complaint against Santiago Montero, Jr., and Charlie Montero, seeking to nullify an Affidavit of Adjudication that transferred the land to Santiago. Elmer argued that Santiago misrepresented himself as the sole heir, despite not being related to Dominga by blood. The assessed value of the property was P3,010.00. The central legal question is whether the Regional Trial Court (RTC) had jurisdiction over the case, given the property’s assessed value, or whether it should have been filed with a lower court.

The respondents, Santiago and Charlie Montero, filed a Motion to Dismiss in the RTC, arguing that the court lacked jurisdiction because the assessed value of the property was below the threshold for RTC jurisdiction. They cited Section 19 of Batas Pambansa Blg. 129, which stipulates that lower courts have exclusive original jurisdiction over cases involving title to or possession of real property when the assessed value does not exceed P20,000.00. Elmer countered that the case was incapable of pecuniary estimation because it primarily sought the cancellation of documents, placing it within the RTC’s jurisdiction. The RTC initially denied the Motion to Dismiss, but the Court of Appeals (CA) reversed this decision, leading to the Supreme Court appeal.

The Supreme Court’s analysis hinged on determining the true nature of the action. The Court reiterated the principle that jurisdiction is determined by the allegations in the complaint and the principal relief sought. It referenced established jurisprudence, stating that an action involving title to real property arises when the cause of action is based on a claim of ownership or the right to exclusive control, possession, enjoyment, or disposition of the property. Furthermore, the Court emphasized that the ultimate objective of the plaintiff dictates the proper venue. “Where the ultimate objective of the plaintiffs is to obtain title to real property, it should be filed in the proper court having jurisdiction over the assessed value of the property subject thereof.”

The Court scrutinized Elmer’s Complaint and found that its core objective was to assert ownership and possession of the property against Santiago and Charlie. Even though the Complaint included a prayer for the cancellation of documents, such as the Affidavit of Adjudication and the Original Certificate of Title (OCT), the Court determined that these were secondary to the primary objective of establishing Elmer’s rightful ownership. The Court quoted from the Complaint, highlighting Elmer’s desire to compel the respondents “to respect the right of ownership and possession over the land in question by the heirs of [Dominga.]”

Building on this principle, the Supreme Court clarified the distinction between “title” and “certificate of title.” Citing Heirs of Generoso Sebe v. Heirs of Veronico Sevilla, the Court explained that a certificate of title is merely evidence of ownership, while title represents the actual right of ownership. The cancellation of a certificate of title is often a consequence of establishing that the defendant lacks genuine title to the property. As the court noted:

Therefore, a plaintiff’s action for cancellation or nullification of a certificate of title may only be a necessary consequence of establishing that the defendant lacks title to real property.

Thus, the action’s primary nature remains one involving title to real property.

The Supreme Court contrasted Elmer’s argument that the cancellation of the OCT was the main objective with the established legal principle that the relief sought dictates jurisdiction. The Court emphasized that the cancellation of the OCT would merely follow the determination of Elmer’s title over the property, making it a secondary consequence rather than the primary objective. “The present action is, therefore, not about the declaration of the nullity of the documents or the reconveyance to the Sebes of the certificates of title covering the two lots. These would merely follow after the trial court shall have first resolved the issue of which between the contending parties is the lawful owner of such lots, the one also entitled to their possession.” This underscored the importance of focusing on the actual relief sought when determining jurisdiction.

Consequently, because the assessed value of the property was P3,010.00, well below the P20,000.00 threshold, the Supreme Court affirmed the Court of Appeals’ decision that the RTC lacked jurisdiction. The proper venue for the case was the Metropolitan Trial Court, Municipal Trial Court, or Municipal Circuit Trial Court. The Supreme Court’s decision reinforces the jurisdictional boundaries set by law and underscores the significance of accurately determining the nature of the action and the principal relief sought in property disputes.

FAQs

What was the key issue in this case?	The key issue was whether the Regional Trial Court (RTC) had jurisdiction over a property dispute, given the property’s assessed value of P3,010.00, or if the case should have been filed in a lower court.
What is the significance of the assessed value?	The assessed value of the property determines which court has jurisdiction over the case. If the assessed value is below P20,000.00 (or P50,000.00 in Metro Manila), the case should be filed in a Metropolitan Trial Court, Municipal Trial Court, or Municipal Circuit Trial Court.
What was Elmer Montero’s main argument?	Elmer Montero argued that the case was incapable of pecuniary estimation because it primarily sought the cancellation of documents, such as the Affidavit of Adjudication and Original Certificate of Title.
How did the Supreme Court rule on this argument?	The Supreme Court ruled that the primary objective of the Complaint was to assert ownership and possession of the property, making the cancellation of documents a secondary consequence.
What is the difference between “title” and “certificate of title”?	“Title” refers to the actual right of ownership, while a “certificate of title” is merely a document that serves as evidence of ownership under the Torrens system of registration.
What was the Court’s ultimate decision?	The Supreme Court affirmed the Court of Appeals’ decision, ruling that the RTC lacked jurisdiction over the case and that it should have been filed in a lower court.
What does it mean for an action to involve “title to real property”?	An action involves “title to real property” when the cause of action is based on a claim of ownership or the right to exclusive control, possession, enjoyment, or disposition of the property.
What law governs the jurisdiction of courts in property disputes?	Batas Pambansa Blg. 129, as amended by Republic Act No. 7691, governs the jurisdiction of courts in property disputes, specifically outlining the thresholds based on the assessed value of the property.

The Supreme Court’s decision in Elmer Montero v. Santiago Montero, Jr. and Charlie Montero serves as a crucial reminder of the importance of jurisdictional rules in property disputes. Accurately assessing the property’s value and understanding the true nature of the action are essential steps in ensuring that cases are filed in the appropriate court. This avoids unnecessary delays and potential dismissals, allowing for a more efficient resolution of property-related conflicts.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: Elmer Montero v. Santiago Montero, Jr. and Charlie Montero, G.R. No. 217755, September 18, 2019