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Copioso vs Copioso
GR No. 149243
October 28, 2002
Facts: Respondents are praying for the reconveyance of the property by virtue of their being
co-owners thereof. Petitioners moved to dismiss the complaint on that ground that it was the
MTC and not the RTC that had jurisdiction considering that the assessed value of the
property was lower than P20,000.00. Petitioners argue that the complaint for reconveyance
cannot be resolved unless the trial court delves upon the issues of “title, possession and
interests” of each of the stakeholders over the subject parcels of land.
Ruling: Yes. Although the assessed value of the two parcels of land involved is P3,770.00,
which is within the jurisdiction of the MTC, the action filed by the respondents is for specific
performance of reconveyance, annulment of contracts and claim for damages, which are
incapable of pecuniary estimation and thus properly within the jurisdiction of the RTC.
If the action affects the title to or possession of real property then it is a real action and
jurisdiction is determined by the assessed value of the property. It is within the jurisdiction
therefore of the Metropolitan Trial Court.
Issue: Whether or not the trial court validly dismissed the complaint.
Ruling: Yes. The trial court considered that neither the assessed value of the lots
(P336,800.00) nor the amount of damages claimed (P102,000.00) exceeded P400,000.00.
In this case, the trial court held itself to be without jurisdiction over the case because the
case fell within the original exclusive jurisdiction of inferior courts pursuant to the provision of
B.P. Blg. 129.
Issue: Whether or not the MTC has jurisdiction over the case of expropriation?
Ruling: No. The SC held that the expropriation proceedings is within the jurisdiction of the
RTC because it is incapable of pecuniary estimation. An expropriation suit does not involve
the recovery of a sum of money. Rather, it deals with the exercise by the government of its
authority and right to take property for public use. As such, it is incapable of pecuniary
estimation and should be filed with the regional trial courts.