Jurisdiction of RTC

De Ungria vs. CA
GR 165777 July 25, 2011

Facts:
On August 26,1999, Rosario Dideles Vda. de
Castor and her children filed with the RTC of
General Santos City a Complaint for
ownership, possession and damages
involving a parcel of land with an alternative
causes of action either:
- to declare two documents (Deed of
Transfer of Rights and Interest and
the Affidavit of Relinquishment) as
patent nullities; and/or
- to recover Rosarios conjugal share
(undivided 1/2 portion of the land)
with damages
Yes. RTC has jurisdiction pursuant to Sec. 19
para. 1 of BP 129, as amended.
"Sec. 19. Jurisdiction in civil cases.
Regional Trial Courts shall exercise exclusive original juri
"(1) In all civil actions in which the subject of the litigation
"(2) In all civil actions which involve the title to, or posses
therein, where the assessed value of the property involve
(P20,000,00) or, for civil actions in Metro Manila, where s
(P50,000.00) except actions for forcible entry into and un
original jurisdiction over which is conferred upon the Metr
Courts, and Municipal Circuit Trial Courts; xxxx

Ceferina De Ungria filed a Motion to Dismiss

on the ground that the RTC has no
jurisdiction over the case for Rosarios failure
to pay the filing fee in full.
- Should be based on the assessed
value of the property:
Php 12, 780.00

RTC denied the Motion of Ceferina.

Ceferina filed a petition for certiorari before

the CA. CA dismissed the petition:
- The RTC did not commit grave abuse
of discretion in denying the motion of
Ceferina. The RTCs order was in
consonance with the Sun Insurance
vs. Asuncion Ruling that if after the
Clerk of Court determines that the
filing fee is still insufficient, the same
shall be considered as a lien on the
judgment that may be entered.
Hence, this petition before the Court.
Issue:
WON the RTC has jurisdiction over the case
despite the alleged non-payment of the correct
docket fees by the plaintiffs (Rosario de Castor,
et. al.)?
Ruling:
Since the subject litigation involves real
property, jurisdiction is determined based on
the assessed value of the property.
The assessed value of the property is Php 12,
780.00. Ideally, the case should fall under the
jurisdiction of MTC pursuant to Sec. 33 (3) of
BP 129, as amended.
However, Rosario filed alternative causes of
action apart from the recovery of the parcel of
land.
Declaration of Nullity of two
documents; and/or
Recovery of Conjugal Share
Hence, the case involves a joinder of causes
of action which comprehends more than the
issue of possession but includes an action to
annul contracts and reconveyance which are
 incapable of pecuniary estimation (Sec. 19
(1) of BP 129 as amended) and is properly
within the jurisdiction of the RTC.

It is not simply the filing of the complaint or

appropriate initiatory pleading, but the
payment of the prescribed docket fee, that
vests a trial court with jurisdiction over the
subject matter or nature of the action.

Since we find that the case involved the

annulment of contract which is not
susceptible of pecuniary estimation, thus,
falling within the jurisdiction of the RTC, the
docket fees should not be based on the
assessed value of the subject land as
claimed by Ceferina, but should be based on
Section 7(b)(1) of Rule 141.

Rosario de Castro was able to pay the

required docket fee. Hence, the RTC has
properly acquired jurisdiction over the
complaint.