8. Heirs of Bautista v. Lindo withdraw all claims and counterclaims against each other.

The
GR No. 208232 compromise was approved by the RTC.
March 10, 2014  Other respondents filed a Motion to Dismiss, alleging that the complaint
By: HAPPY failed to state the value of the property sought to be recovered.
Topic: Jurisdiction o They asserted that the total selling price of all the properties is
Petitioners: SURVIVING HEIRS OF ALFREDO R. BAUTISTA, namely: EPIFANIA G. only P16,500 and the selling price or market value of a property
BAUTISTA and ZOEY G. BAUTISTA is always higher than its assessed value.
Respondents: FRANCISCO LINDO and WELHILMINA LINDO; and HEIRS OF FILIPINA o Since BP 129, as amended, grants jurisdiction to the RTCs over
DAQUIGAN, namely: MA. LOURDES DAQUIGAN, IMELDA CATHERINE DAQUIGAN, civil actions involving title to or possession of real property or
IMELDA DAQUIGAN and CORSINO DAQUIGAN, REBECCA QUIAMCO and ANDRES interest therein where the assessed value is more than
QUIAMCO, ROMULO LORICA and DELIA LORICA, GEORGE CAJES and LAURA CAJES, P20,000, then the RTC has no jurisdiction over the complaint in
MELIDA BAÑEZ and FRANCISCO BAÑEZ, MELANIE GOFREDO, GERVACIO CAJES and question since the property which Bautista seeks to repurchase
ISABEL CAJES, EGMEDIO SEGOVIA and VERGINIA SEGOVIA, ELSA N. SAM, PEDRO M. is below the P20,000 jurisdictional ceiling.
SAM and LINA SAM, SANTIAGO MENDEZ and MINA MENDEZ, HELEN M. BURTON  RTC dismissed the complaint for lack of jurisdiction.
and LEONARDO BURTON, JOSE JACINTO and BIENVENIDA JACINTO, IMELDA o Bautista failed to allege in his complaint that the value of the
DAQUIGAN, LEO MATIGA and ALICIA MATIGA, FLORENCIO ACEDO JR., and LYLA subject property exceeds P20,000.
VALERIO o What was only stated was that the total and full refund of the
Ponente: Velasco, Jr., J. purchase price of the property is P16,500. This omission was
considered by the RTC as fatal to the case considering that in
RECIT-READY SUMMARY: real actions, jurisdictional amount is determinative of whether
it is the MTC or the RTC that has jurisdiction over the case.
o With respect to the belated filing of the motion, the RTC held
that a motion to dismiss for lack of jurisdiction may be filed at
DOCTRINE: Jurisdiction of courts is granted by the Constitution and pertinent laws.
any stage of the proceedings, even on appeal, and is not lost by
waiver or by estoppel.
It is a well-settled rule that jurisdiction of the court is determined by the allegations
in the complaint and character of the relief sought.  Hence, this petition.

Facts: Issue:
 Alfredo Bautista inherited a free-patent land. He subdivided the property  W/N RTC has jurisdiction over the complaint
and sold it to several vendees, herein respondents, via a notarized deed  W/N the action filed by petitioners is one involving title to or possession
of absolute sale. TCTs were issued in favor of the vendees. of real property or any interest therein or one incapable of pecuniary
 3 years after the sale, Bautista filed a complaint for repurchase against estimation.
respondents before the RTC, anchoring his cause of action on Section 199
of Commonwealth Act No. 141 or the Public Land Act. Held/Ratio:
 Respondent, in their answer, raised lack of cause of action, estoppel,  YES, RTC has jurisdiction. The action is incapable of pecuniary
prescription and laches, as defenses. estimation. The complaint to redeem a land subject of a free patent is a
civil action incapable of pecuniary estimation.
 Meanwhile, Bautista died and was substituted by Epifania G. Bautista.
 It is a well-settled rule that jurisdiction of the court is determined by the
 Respondents Francisco and Welhilmona Lindo later entered into a
allegations in the complaint and character of the relief sought.
compromise agreement with petitioners. They agreed to cede to Epifania
a potion of the property as well as to waive, abandon, surrender and  In determining whether an action is one of the subject matter of which is
not capable of pecuniary estimation, this Court has adopted the criterion
of first ascertaining the nature of the principal action or remedy sought.
 o If it is primarily for the recovery of a sum of money, the claim is  Even if we treat the present action as one involving title to real property
considered capable of pecuniary estimation, and whether or an interest therein which falls under the jurisdiction of the first level
jurisdiction is in the municipal courts or in the RTCs would court under Sec. 33 of BP 129, as the total selling price is only PhP16,000
depend on the amount of the claim. way below the PhP20,000 ceiling, still, the postulation of respondents
o But where the basic issue is something other than the right to that MTC has jurisdiction will not hold water.
recover a sum of money, where the money claim is purely  This is because respondents have actually participated in the proceedings
incidental to, or a consequence of, the principal relief sought, before the RTC and aggressively defended their position, and by virtue of
this Court has considered such actions as cases where the which they are already barred to question the jurisdiction of the RTC
subject of the litigation may not be estimated in terms of following the principle of jurisdiction by estoppel.
money, and, hence, are incapable of pecuniary estimation.  The party raising defenses to the complaint, actively participating in the
These cases are cognizable exclusively by RTCs. proceedings by ling pleadings, presenting his evidence, and invoking its
 The facts are clear that Bautista sold to respondents his lots which were authority by asking for an affirmative relief is deemed estopped from
covered by a free patent. While the deeds of sale do not explicitly contain questioning the jurisdiction of the court. Respondents actively
the stipulation that the sale is subject to repurchase by the applicant participated in the proceedings
within a period of 5 years from the date of conveyance pursuant to Sec. o By filing their Answer and Opposition to the Prayer for
119 of CA 141, still, such legal provision is deemed integrated and made Injunction;
part of the deed of sale as prescribed by law. o By participating in Pre-trial;
 It is basic that the law is deemed written into every contract. Although a o By moving for the postponement of their presentation of
contract is the law between the parties, the provisions of positive law evidence;
which regulate contracts are deemed written therein and shall limit and o By presenting their witness;
govern the relations between the parties. Thus, it is a binding prestation o By submitting the compromise agreement for approval.
in favor of Bautista which he may seek to enforce. That is precisely what  Having fully participated in all stages of the case, and even invoking the
he did. He filed a complaint to enforce his right granted by law to recover RTC's authority by asking for affirmative reliefs, respondents can no
the lot subject of free patent. Ergo, it is clear that his action is for specific longer assail the jurisdiction of the said trial court. Simply put,
performance, or if not strictly such action, then it is akin or analogous to considering the extent of their participation in the case, they are, as they
one of specific performance. Such being the case, his action for specific should be, considered estopped from raising lack of jurisdiction as a
performance is incapable of pecuniary estimation and cognizable by the ground for the dismissal of the action.
RTC. Petition GRANTED.
 At first blush, it appears that the action filed by Bautista involves title to
or possession of the lots he sold to respondents. Since the total selling Notes:
price is less than PhP20,000, then the MTC, not the RTC, has jurisdiction  Settled jurisprudence considers some civil actions as incapable of
over the case. pecuniary estimation, viz.:
 This proposition is incorrect for the re-acquisition of the lots by Bautista o Actions for specific performance;
or herein successors-in-interests, the present petitioners, is but incidental o Actions for support which will require the determination of the
to and an offshoot of the exercise of the right by the latter to redeem said civil status;
lots pursuant to Sec. 119 of CA 141. o The right to support of the plaintiff;
 The reconveyance of the title to petitioners is solely dependent on the o Those for the annulment of decisions of lower courts;
exercise of such right to repurchase the lots in question and is not the o Those for the rescission or reformation of contracts;
principal or main relief or remedy sought. Thus, the action of petitioners o Interpretation of a contractual stipulation.
is, in reality, incapable of pecuniary estimation, and the reconveyance of
the lot is merely the outcome of the performance of the obligation to  The Court finds that the instant cause of action to redeem the land is one
return the property conformably to the express provision of CA 141. for specific performance.