MENDOZA v. TEH G.R. No.

122646/ MARCH 14,

1997/ FRANCISCO, J./

SUMMARY . Adelia filed a complaint with the Batangas

RTC for reconveyance of property on behalf of the
intestate estate of her deceased husband,
simultaneously asking for appointment as
administratrix thereof. Respondents opposed,
claiming that since the deceased had lived in QC, the
QC RTC was the proper court. RTC Batangas
dismissed the case. SC held that the respondents had
mistaken venue with jurisdiction. BP 129 clearly
grants the RTC jurisdiction over a complaint for
reconveyance of property (over P20k) and for
complaints incapable of pecuniary estimation, such as
seeking appointment as administratrix. Furthermore,
this case did not involve the settlement of an estate,
hence no need for the limited jurisdiction of a
probate court, so Judge Teh shouldn’t have dismissed
the complaint for lack of jurisdiction.
DOCTRINE. Venue is not the same as jurisdiction. The
location of property affects venue, but its value or the
nature of the remedy sought affects jurisdiction, which
is conferred by law.