Russell v. Vestil

Summary

This case involves a jurisdictional dispute over an action filed by co-heirs seeking to nullify a partition document and obtain proper partition of inherited property. The Regional Trial Court dismissed the case for lack of jurisdiction, ruling it belonged to the Municipal Circuit Trial Court based on the property's low assessed value of P5,000.00. The Supreme Court reversed, holding that the primary action was for annulment of a document, which is incapable of pecuniary estimation and thus within RTC jurisdiction under Section 19(1) of B.P. 129. The Court applied the principle that jurisdiction depends on the nature of the principal relief sought, not incidental claims. Since nullification of the partition document was the main objective with property partition being merely consequential, the case properly belonged to the RTC. The decision clarifies the distinction between actions involving property title/possession based on assessed value versus actions incapable of pecuniary estimation.