Civil Procedure: Case Digest Recit Version (September 14, 2023)

Ignacio vs. CFI of Bulacan, 42 SCRA 89 | Jurisdiction, Subject Matter

Alipio Marcelo leased land from Felizardo Lipana until his death. Maximo Marcelo initially claimed tenancy rights and filed a case in the CAR against Lipana, but Lipana intended to recognize Magdalena dela Cruz as the rightful tenant. Maximo eventually conceded his rights in a compromise agreement.

However, Magdalena dela Cruz later filed a complaint asserting her tenancy rights in the CAR, prompting Lipana to file an action for ejectment and forcible entry in the Municipal Court.

The Municipal Court ruled in Lipana's favor, ordering Magdalena dela Cruz and her husband Lorenzo Ignacio to vacate the premises and remove their house.

CFI: Upheld the decision of the Municipal Court.

Issue: WoN the lower courts has jurisdiction over the subject matter of the case. NO.

The court noted that these cases essentially revolve around a tenancy dispute, and the issue of actual possession was not resolved by the Court of Agrarian Relations. The decision and writ of execution only affected Maximo Marcelo's claim as a tenant and did not address Magdalena dela Cruz's right to possession. The ejectment case intruded upon the jurisdiction of the Court of Agrarian Relations.

Principle: 

While it is true that the jurisdiction of the court in a suit for ejectment or forcible entry is determined by the allegations in the complaint, yet where tenancy is averred as a defense and, upon hearing, is shown to be the real issue, the court should dismiss the case for want of jurisdiction.

Salmorin vs. Zaldivar, G.R. No. 169691, Jul. 23, 2008 | Jurisdiction, Subject Matter

Dr. Pedro Zaldivar entered into an agreement with Pedrito Salmorin,

designating him as the administrator of his lot with a monthly salary of ₱150. Salmorin allegedly failed to comply with the terms of the agreement, leading Zaldivar to terminate his services and file a complaint for unlawful detainer against Salmorin.

Salmorin claimed the existence of a tenancy relationship between them, arguing that the case was an agrarian matter.

MCTC: Dismissed the case for lack of jurisdiction, considering it an agrarian dispute.
RTC: Ruled in favor of Zaldivar upon appeal, stating that there was no tenancy relationship.
CA: Upheld the RTC decision.

Issue: WoN the regular court had no jurisdiction over the case. NO.

The Court noted that Zaldivar’s complaint concerned the unlawful detainer by Salmorin of the subject lot. This matter is properly within the jurisdiction of the regular courts. 

A tenancy relationship cannot be presumed. . In this case, the RTC and CA correctly found that the third and sixth elements, namely, consent of the landowner and sharing of the harvests, respectively, were absent.

Principle:

The jurisdiction of the court over the nature of the action and the subject matter thereof cannot be made to depend upon the defenses set up in the court or upon a motion to dismiss. Otherwise, the question of jurisdiction would depend almost entirely on the defendant. 

Paat vs. Court of Appeals, 266 SCRA 167 | Jurisdiction,    Doctrine of Primary Jurisdiction

Victoria de Guzman's truck was seized by DENR in Aritao, Nueva Vizcaya due to lack of required documents for concealed forest products.

The CENRO issued a confiscation order, giving her 15 days to explain, but she did not respond. The Regional Executive Director then ordered forfeiture of the truck. 

Private respondents sought reconsideration which was denied leading to the filing replevin suit against DENR officials before the RTC. 

Issue: WoN an action for replevin prosper to recover a movable property which is the subject matter of an administrative forfeiture proceeding in DENR. NO.

It is important to point out that the enforcement of forestry laws, rules and regulations and the protection, development and management of forest lands fall within the primary and special responsibilities of the Department of Environment and Natural Resources. 

Principle:

The doctrine of primary jurisdiction does not warrant a court to arrogate unto itself the authority to resolve a controversy the jurisdiction over which is initially lodged with an administrative body of special competence. The Secretary of DENR is directed to resolve the controversy with utmost dispatch.

Rombe Eximtrade vs. Asiatrust Dev’t. Bank, GR 164479, Feb. 13, 2008 | Doctrine of Judicial Stability

Rombe Eximtrade filed for a Declaration of a State of Suspension of Payments with Approval of Proposed Rehabilitation Plan in RTC Branch 7, leading to a Stay Order. 

The Securities and Exchange Commission and other creditors opposed the petition, which was eventually dismissed due to Rombe's misrepresentations and insolvency. 

Asiatrust Development Bank then initiated foreclosure proceedings in RTC Branch 15. Rombe sought to annul foreclosure-related documents, obtaining a Temporary Restraining Order (TRO) from RTC Branch 15. The Court of Appeals (CA) later ruled in favor of Asiatrust, annulling the TRO, prompting Rombe to challenge the CA's decision with a petition to the Supreme Court.

Issue:  WoN the RTC Branch 15 in granting the TRO interfered with and set aside the earlier Order of the RTC Branch 7. NO.

There is no interference between co-equal courts in cases involving corporate rehabilitation and extrajudicial foreclosure suspension.

• Corporate rehabilitation case is summary and non-adversarial.
• Annulment of foreclosure case follows regular civil procedure rules.

Being different in nature, purpose, and reliefs sought, the injunctive order in one case does not interfere with the other. Also, RTC Branch 15 did not intervene with the rehabilitation case since it was already dismissed and final.

Principle:

There is no interference by one co-equal court with another when the case filed in one involves corporate rehabilitation and suspension of extrajudicial foreclosure in the other.

The rehabilitation case is a special proceeding which is summary and non-adversarial in nature. The annulment of foreclosure case is an ordinary civil action.

Tijam vs. Sibonghanoy, 23 SCRA 29 | Estoppel by Laches

In June 1948, the Judiciary Act of 1948 was enacted. Just a month after its passage, Sps. Tijam initiated a civil case in the CFI-Cebu against Sps. Sibonghanoy to recover P1,908.00. A writ of attachment was initially issued but dissolved later after the defendants and Manila Surety and Fidelity Co., Inc. posted a counter-bond.

The CFI ruled in favor of the Sps. Tijam and issued a writ of execution against the defendants and Manila Surety. Manila Surety objected, citing the lack of notice, and requested relief from liability. Initially, the writ was denied, but it was eventually granted after a proper notice.

In 1962, 14 years later, Manila Surety appealed to the CA, which affirmed the CFI's decision. 

The following year, Manila Surety filed a motion to dismiss, arguing that the CFI Cebu did not have jurisdiction over the case because the Judiciary Act of 1948 placed actions with demands not exceeding P2000 in the inferior courts, not the CFI.

Issue: WoN Manila Surety is barred from raising the jurisdictional issue by laches. YES.

General Rule: 

• Jurisdiction over the subject matter is conferred upon the courts exclusively by law. 
• The lack of it affects the authority of the court to take cognizance of the case. 
• Objection may be raised at any stage of the proceedings. 

Exception: A party may be barred by laches from raising this objection for the first time on appeal, especially when they have actively participated in the case.

Principle:

Laches, in a general sense, is failure or neglect, for an unreasonable and unexplained length of time, to do that which, by exercising due diligence, could or should have been done earlier.

Ortigas and Co., Ltd Partnership vs. Herrera, 120 SCRA 89 | Jurisdiction, RTC

Ortigas and Co., Ltd Partnership and the respondent had a contract for sale with a condition: if the respondent construct a house within two years, Ortigas would refund P10.00 per sqm. When the condition was met, the respondent sought a P4,820.00 refund, which Ortigas did not pay.

The respondent filed a complaint in the City Court of Manila. Ortigas moved to dismiss, claiming lack of jurisdiction and other grounds. The City Court Judge Jose Herrera deferred judgment until after the trial.

Ortigas then filed a special civil action in the Court of First Instance, which was dismissed due to the claim's value being less than P10,000. Ortigas argued that the city court lacked jurisdiction, because it was a specific performance case not subject to pecuniary estimation, exclusively under the Court of First Instance.

Issue: WoN the City Court of Manila has jurisdiction over the complaint. NO

The court agreed with the petitioner, ruling that the city court lacked jurisdiction because the action was for specific performance, not a sum of money, and therefore not subject to pecuniary estimation.

Principle:

When a party to a contract has agreed to refund to the other party a sum of money upon compliance by the latter of certain conditions and only upon compliance therewith may what is legally due him under the written contract be demanded, the action is one not capable of pecuniary estimation. The payment of a sum of money is only incidental which can only be ordered after a determination of certain acts the performance of which being the more basic issue to be inquired into.

Sandoval vs. Caneba, 190 SCRA 77 | Jurisdiction, HLURB

Private respondent Estate Developers & Investors Corporation filed a complaint for the collection of unpaid installments for a subdivision lot in the Regional Trial Court (RTC) of Manila. The RTC rendered a decision in favor of the corporation.

Petitioner Nestor Sandoval filed a motion to vacate judgment and to dismiss the complaint. He argued that the court lacked jurisdiction. The RTC denied the motion, and a writ of execution was issued.

The petitioner filed a petition, claiming the RTC had no jurisdiction because the case fell under the exclusive authority of the Housing and Land Use Regulatory Board (HLURB) according to Presidential Decree No. 957.

Issue: WoN ordinary courts have jurisdiction over the collection of unpaid installments regarding a subdivision lot. NO.

Under Presidential Decree No. 957, the National Housing Authority (NHA), later renamed the Housing and Land Use Regulatory Board (HLURB), has exclusive jurisdiction over certain cases, including disputes related to unpaid installments for subdivision lots.

CT Torres Enterprises, Inc. vs. Hibionada, 191 SCRA 268 | Jurisdiction, HLURB

CT Torres Enterprises, Inc., as an agent of private respondent Pleasantville Development Corporation, sold a subdivision lot on installment to private respondent Efren Diongon. 

After completing the installment payments, Diongon demanded the delivery of the certificate of title to the subject land. When neither the petitioner nor Pleasantville complied, he filed a complaint against them for specific performance and damages in the Regional Trial Court of Negros Occidental.

CT Torres Enterprises filed a motion to dismiss for lack of jurisdiction, contending that the competent body to hear and decide the case was the Housing and Land Use Regulatory Board (HLURB). The RTC denied the motion, stating that the case fell under the Civil Code and, therefore, its jurisdiction.

Issue: WoN ordinary courts have jurisdiction over the matter. NO.

The complaint filed by Diongon falls under the jurisdiction of the HLURB, as it involves specific performance of a contract related to a subdivision lot.

The argument that only courts can adjudicate claims under the Civil Code is outdated, as many administrative agencies now exercise quasi-judicial authority to address complex or specialized issues. This delegation of power aims to expedite the resolution of such issues.

Cuenca vs. PCGG, G.R. No. 159104-05, Oct. 5, 2007 | Jurisdiction, Sandiganbayan

In 1978, petitioner Rodolfo M. Cuenca and his family’s holding company, Cuenca Investment Corporation (CIC), negotiated and reached an agreement with respondents Independent Realty Corporation (IRC) and Universal Holdings Corporation (UHC), whereby petitioners Cuenca and CIC would purchase all the shares of stock and subscription rights of IRC in UHC for PhP 10,000,000 and assume IRC’s unpaid subscription of PhP 30,000,000.

Political changes in 1986 led to the sequestration of IRC and UHC by Presidential Commission on Good Government.

In 1991, petitioners filed a case to transfer IRC's UHC shares or recover assets. The Makati RTC first denied jurisdiction-based motions but later denied them, citing PCGG absence and pre-PCGG transaction. RTC ruled for petitioners, ordering IRC and UHC to return shares.

IRC and UHC appealed to the CA, claiming Sandiganbayan's exclusive jurisdiction due to sequestration. CA reversed RTC, citing Sandiganbayan's exclusive jurisdiction and applying conclusiveness of judgment.

Issue: WoN Sandiganbayan has exclusive jurisdiction over the subject matter of the case. YES.

Sandiganbayan has exclusive jurisdiction over the case.

The subject matter of Civil Case No. 91-2721 before the Makati City RTC overlaps with the ill-gotten wealth case, Civil Case No. 0016 before the Sandiganbayan.

The legal ownership of UHC or PNCC shares would be transferred to petitioners, affecting the government's ownership rights. The ownership dispute over sequestered companies' shares is related to the recovery of alleged ill-gotten wealth, falling under Sandiganbayan's exclusive jurisdiction. PCGG's intervention in the case satisfies the requirement for exclusive Sandiganbayan jurisdiction.

Fajardo vs. Bautista, 232 SCRA 29 | Jurisdiction, HLURB

Petitioners entered into "Contracts to Sell" agreements with Sps. Jareño, owners and developers of Calamba Central Compound, and another contract with Fernando Realty and Development Corporation (FERNANDO) for lot purchases. Contracts stated that upon full payment, sellers would transfer titles to buyers.

Jareños sold lots to Ruben Habacon using "Kasulatan ng Bilihan." Habacon canceled certificates of title for the lots and had new ones issued in his name.

Petitioners filed complaints to annul sales and reinstate canceled certificates. Trial court dismissed the complaints, citing P.D. No. 957, as amended by P.D. No. 1344, granting jurisdiction to the Housing and Land Use Regulatory Board (HLRB) for cases of "unsound real estate business practices."

Issue: WoN ordinary courts have jurisdiction over the matter. NO.

The court upheld the trial court's ruling that Section 19(2) of B.P. Blg. 129, a general law, should yield to P.D. No. 957, as amended by P.D. No. 1344, which was a special law specific to real estate business practices.

Jurisdiction belonged to the National Housing Authority (NHA) under P.D. No. 957, which was later transferred to the Housing and Land Use Regulatory Board (HLRB). The complaints involved unsound real estate business practices and specific performance of contractual and statutory obligations, falling under the jurisdiction of the HLRB.

The claims for annulment of the sales and certificates of title and damages were merely incidental.

Benguet Corp. vs. Leviste, 204 SCRA 99 | Jurisdiction, Bureau of Mines and Geo-Sciences

Private respondent Helen Dizon-Reyes filed an action for the annulment of an operations agreement against Benguet Corporation and Dizon Copper-Silver Mines, Inc.

Benguet filed a motion to dismiss, citing jurisdictional issues, which the trial court denied.

Benguet filed a petition for certiorari, arguing that the RTC lacks jurisdiction and that the case should fall under the Bureau of Mines and Geo-Sciences' jurisdiction.

Issue: WoN the RTC has jurisdiction to take cognizance of an action for annulment of operations agreement entered into by and between two mining companies. NO.

The Court ruled that P.D. No. 1281 vests the Bureau of Mines and Geo-Sciences with jurisdiction over mining-related matters, including the cancellation of mining contracts due to refusal to abide by their terms. The jurisdiction of the RTC is, therefore, inappropriate in this case, and the case should have been brought before the Bureau.

Machete vs. Court of Appeals, 250 SCRA 176 | Jurisdiction, DAR

Celestino Villalon filed a complaint against Lope Machete and others for the collection of back rentals and damages from a leasehold agreement of an agricultural land in Carmen, Bohol.

Petitioners failed to pay their rentals as agreed upon.

The trial court dismissed the case, stating it was within the jurisdiction of the Department of Agrarian Reform (DAR). The Court of Appeals reversed this decision, emphasizing that the case wasn't an agrarian dispute.

Issue: WoN RTC is vested with jurisdiction over cases for collection of back rentals from leasehold tenants. NO.

The Supreme Court agreed with the trial court, reiterating that agrarian reform matters should be handled by the DAR. However, the case was not entirely lost for the respondent, as the DAR was better equipped to resolve agrarian disputes quickly and inexpensively. The case was referred back to the appropriate Department of Agrarian Reform Adjudication Board (DARAB) for adjudication.

Bernardo vs. Caltex Phil. Inc. 216 SCRA 170 | Jurisdiction, Energy Regulatory Board

Nonito J. Bernardo operates two Caltex gasoline stations.Bernardo placed orders for 10,000 liters of diesel fuel and 10,000 liters of premium gasoline with Caltex's Pandacan Terminal and made full payments for both orders.

Despite payment, Caltex did not deliver the petroleum products as ordered, citing a computer system malfunction and a price increase announced by the Energy Regulatory Board.

Bernardo filed a complaint in the Regional Trial Court at Quezon City, seeking delivery of the petroleum products and damages. Caltex moved to dismiss the complaint, claiming that the court lacked jurisdiction. The Trial Court eventually dismissed Bernardo's suit for lack of jurisdiction, citing a judgment from the Court of Appeals and the jurisdiction of the Energy Regulatory Board.

Issue: WoN the Energy Regulatory Board has jurisdiction over the instant case. NO.

The Supreme Court rules that the RTC has jurisdiction.

Caltex had become a debtor to Bernardo, and the dispute was about how Caltex should fulfill its obligation. The main issue was the pricing of petroleum products, and it did not fall within the jurisdiction of the Energy Regulatory Board. Instead, it was a civil law question to be determined by the Regional Trial Court.

People vs. Yadao, G.R. Nos. 162144-54, Nov. 13, 2012 | Jurisdiction, Family Courts

This case involves the alleged summary execution of suspected Kuratong Baleleng Gang members, led by police officers, including Panfilo M. Lacson, resulting in the deaths of 11 suspects. 

Murder charges were filed against the officers, leading to a series of legal proceedings and the assignment of the case to Judge Ma. Theresa L. Yadao in Branch 81 of the RTC. The prosecution requested the case be transferred to family courts due to involvement of minors as victims, but Judge Yadao denied this request. Judge Yadao dismissed the cases, citing a lack of probable cause and inconsistent affidavits from prosecution witnesses. 

Issue: WoN Judge Yadao gravely abused her discretion when she took cognizance of criminal cases contrary to the prosecution’s view that such cases fell under the jurisdiction of family courts. NO.

The prosecution cites Section 5 of R.A. 8369, which grants family courts jurisdiction over cases involving minors. However, the Court notes that the primary objective of vesting family courts with jurisdiction in such cases is to protect the welfare and best interests of minors. Since the two minor victims in this case are deceased and represented by their parents as private offended parties, there is no living minor involved in the murder cases requiring the special protection of a family court.

Vda. De Barrera vs. Heirs of Legaspi, G.R. No. 174346, Sept. 12, 2008 | Jurisdiction, MCTC

Petitioner Johnny Oco Jr., accompanied by unidentified CAFGU members, forcibly entered a 0.9504-hectare irrigated farmland in Misamis Occidental. He dispossessed the respondents and destroyed the planted crops.

In response, the heirs of Vicente Legaspi filed a complaint for Reconveyance of Possession with Preliminary Mandatory Injunction and Damages against the petitioners.

The petitioners argued that the land was part of a three-hectare property initially owned by Andrea Lacson, which had been sold to various individuals, including petitioner Fernanda Geonzon vda. de Barrera. The respondents claimed that the land had been possessed and cultivated by their predecessor-in-interest, Vicente Legaspi, and his wife Lorenza since 1935.

The trial court ruled in favor of the respondents, ordering the return of the land's possession to them. The Court of Appeals affirmed the trial court's decision.

Issue: WoN the RTC has jurisdiction over the subject matter of the complaint, the assessed value of the land being only P11,160, as reflected in Tax Declaration . NO.

The Supreme Court found that the court had no jurisdiction over the case because the assessed value of the land was only P11,160, falling within the jurisdiction of the municipal trial court. 

According to BP 129 Sec. 33, municipal trial courts have exclusive original jurisdiction in civil actions involving title to or possession of real property where the assessed value of the property does not exceed P20,000 or P50,000 in cases filed in Metro Manila. 

Therefore, all proceedings in the Regional Trial Court were declared null and void, and the complaint was dismissed.