VALUE OF THE REALTY PROPERTY WITHIN THE JURISDICTION OF THE MTCC

GOVERNING PROVISION:

Republic Act No. 7691 March 25, 1994

AN ACT EXPANDING THE JURISDICTION OF THE METROPOLITAN TRIAL COURTS,

MUNICIPAL TRIAL COURTS, AND MUNICIPAL CIRCUIT TRIAL COURTS, AMENDING
FOR THE PURPOSE BATAS PAMBANSA, BLG. 129, OTHERWISE KNOWN AS THE
"JUDICIARY REORGANIZATION ACT OF 1980"

Section 4. Section 34 of the same law is hereby amended to read as follows:

"Sec. 34. Delegated Jurisdiction in Cadastral and Land Registration Cases. –

Metropolitan Trial Courts, Municipal Trial Courts, and Municipal Circuit Trial
Courts may be assigned by the Supreme Court to hear and determine
cadastral or land registration cases covering lots where there is no
controversy or opposition, or contested lots where the value of which does
not exceed One hundred thousand pesos (P100,000.00), such value to be
ascertained by the affidavit of the claimant or by agreement of the respective
claimants if there are more than one, or from the corresponding tax
declaration of the real property. Their decisions in these cases shall be
appealable in the same manner as decisions of the Regional Trial Courts."

RELATED JURISPRUDENCE:
The nature of an action is not determined by what is stated in the caption of the
complaint but by the allegations of the complaint and the reliefs prayed for. Where, as in
this case, 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. (Huguete vs. Embudo, 405 SCRA 273, G.R. No. 149554 July 1, 2003).

In a case of a more recent vintage, a complaint was filed in the MTC for
reconveyance of real property (with an assessed value of ₱12,400.00) with declaration of
nullity of certificate of title (OCT), having been allegedly obtained by fraud. On the issue
of whether or not the case should have been filed in the RTC because it involved a
subject matter incapable of pecuniary estimation, the Court held that the same was a real
action because the primary relief was to recover ownership of real property. Considering
its assessed value, the MTC had properly exercised jurisdiction over the over the action
(Maslag v. Monzon, G.R. No. 174908, June 17, 2013).

APPLICATION TO THE FACTS OF THE CASE:

The Heirs of Teofisto Basarte ultimately sought to annul the Deed of Absolute Sale
between Jose Basarte and Balbina Basarte Gurro so that the title acquired by Balbina
Basarte Gurro based on the sale will be nullified. The nullification will give way for the
heirs of Teofisto Basarte to acquire or inherit the specific portion that they are entitled to
which is 1/5 of the subject parcel of land. Thus, the heirs of Teofisto Basarte have the
primary purpose to obtain title to the real property by reconveyance. The current assessed
value of the subject property is ₱7,690.00 as indicated in the Tax Declaration No. G-
174565 issued in 2008 under the name of Balbina Basarte Balbina (Annex “L” of the
Complaint). Thus, MTC has jurisdiction over real actions where the value of which does
not exceed ₱100,000.00. In the case at bar, the property in question is within the court’s
jurisdiction based on the 2008 tax declaration.