Civil Procedure: Jurisdiction

1.     Jurisdiction of the Supreme Court

• The highest court of the land is the Supreme Court.
• It was not affected by the Judiciary Law (BP 129) which reorganized the judiciary in 1983. 
• Being a constitutional court, its jurisdiction is found in the fundamental law itself. 
• The SC is both an original and appellate court.

Composition

• It is composed of the Chief Justice and 14 Associate Justices.
• The Constitution ordains that the President appoints the members of the SC and judges of lower courts from a list of at least three nominees prepared by the JBC for every vacancy and requires the President to issue appointments, for lower courts, within 90 days from submission of the list (Art. VIII, Sec. 9) and to fill the vacancy of the SC within 90 days from its occurrence. (Art. VIII, Sec. 4(1)). All such appointments need no confirmation.

Divisions and En Banc

• The SC sits either en banc or in divisions of 3, 5 or 7 members. 
• At present, it has 3 divisions of 5 members each.
• A decision or resolution of a division, when concurred in by a majority of its members who actually took part in the deliberations on the issues in a case and voted thereon, and in no case without the concurrence of at least 3 of such members, is a decision or resolution of the SC. (Art. VIII, Sec. 4(3)).
• The Court en banc is not an appellate court to which decisions or resolutions of a division may be appealed. (Circular No. 2-89 effective March 1, 1989) 
• No doctrine or principle of law laid down by the court in a decision rendered en banc or in division may be modified or reversed except by the court sitting en banc. (Art. VIII, Sec. 4(3))

How a Case Before a Division is Referred to the Court en banc 

• At any time after a Division takes cognizance of a case and before a judgment or resolution therein rendered becomes final and executor, the Division may refer the case en consulta to the court en banc which, after consideration of the reasons of the division for such referral, may return the case to the Division or accept the case for decision or resolution.
• Cases assigned to a Division including motions for reconsideration which in the opinion of at least 3 members merit the attention of the court en banc and are accepted by the majority vote of the actual members of the court en banc may be considered as en banc cases. 
• A resolution of the Division denying a party’s motion for referral to the Court en banc of any division shall be final and not appealable to the Court en banc. 
• When a decision or resolution is referred by a division to the Court en banc, the latter may in the absence of sufficiently important reasons decline to take cognizance of the same, in which case, the decision or resolution shall be returned to the referring Division. (Circular No. 2-89 effective March 1, 1989) 

En Banc Cases 

• In a resolution dated February 23, 1984, the following are considered en banc cases: 
1. Cases in which the constitutionality or validity of any treaty, executive agreement, law, ordinance or executive order or regulation is in question; 
2. Criminal cases in which the decision imposes the death penalty;
3. Cases raising novel questions of law;
4. Cases affecting ambassadors, public ministers and consuls; 
5. Cases where a doctrine or principle laid down by the court en banc or in division may be modified or reversed;
6. Cases assigned to a division including motions for reconsideration which in the opinion of at least 3 members merit the attention of the Court en banc and are acceptable to a majority vote of the actual membership of the Court en banc;
7. All other cases as the Court en banc by a majority of its actual membership may deem of sufficient importance to merit its attention;
8. Cases where the penalty to be imposed is the dismissal of a judge, officer, or employee of the SC, disbarment of a lawyer, or suspension of any of them for a period of more than one year or a fine of P10,000.00, or both;
9. Cases involving decisions, resolutions or orders of the Sandiganbayan, Comelec, COA, or Military Tribunals;
10. Habeas corpus against government or military officials;

Principal Functions of the Supreme Court 

1. Adjudication (Judicial Power)
2. Administration or Disciplinary power
3. Rule-making (Rule-making Power)

ORIGINAL JURISDICTION OF THE SUPREME COURT 

(Art. VIII, Sec. 5(1))

The Supreme Court shall have the following powers: 

[1] Exercise original jurisdiction over cases affecting ambassadors, other public ministers and consuls, over petitions for certiorari, prohibition, mandamus, quo warranto, and habeas corpus. 

Note that the foregoing provision does not define the original jurisdiction of the SC as exclusive, hence it can be concurrent or exclusive.

When is it exclusive and when concurrent? 

 

Original Exclusive 

• Issuance of writs of certiorari, prohibition and mandamus as defined in Rule 65 against the following:
1. CA; 
2. COMELEC; 
3. COA; 
4. Sandiganbayan;
5. Court of Tax Appeals (because it has now the same rank as the CA).

Original Concurrent 

• With CA – 
• petitions for the issuance of writs of certiorari, prohibition, and mandamus against the following: 
1. CSC;
2. Central Board of Assessment Appeals;
3. NLRC or the Secretary of Labor under the Labor Code;
4. Quasi-judicial agencies;
5. RTC.
• With RTC – 
• actions affecting ambassadors and other public ministers and consuls.
• With CA and RTC – 
• habeas corpus, quo warranto, and writs of certiorari, prohibition, and mandamus against inferior courts and bodies.
• With CA, RTC and Sandiganbayan  – 
• petitions for issuance of writ of Amparo and petitions for Habeas Data, where the action involves public data or government office.
• With SC and Sandiganbayan –
• petitions for certiorari, prohibition, mandamus, habeas corpus, injunction and other ancillary writs in aid of the Sandiganbayan's appellate jurisdiction  i.e. only in connection with a case appealed to the Sandiganbayan.

APPELLATE JURISDICTION OF THE SUPREME COURT

(Art. VIII, Sec. 5(2))

The Supreme Court shall have the following powers: 

[2]  Review, revise, reverse, modify, or affirm on appeal or certiorari, as the law or the Rules of Court may provide, final judgments and orders of lower courts in:

a) All cases in which the constitutionality or validity of any treaty, international or executive 

agreement, law, presidential decree, proclamation, order, instruction, ordinance, or regulation is in question.

b) All cases involving the legality of any tax, impost, assessment, or toll, or any  penalty imposed in relation thereto.

c) All cases in which the jurisdiction of any lower court is in issue.

d) All criminal cases in which the penalty imposed is reclusion perpetua or higher.

e) All cases in which an error or question of law is involved.

If (a), (b), and (c) also involve questions of facts or mixed questions of fact and of law, the aggrieved party shall appeal to the Court of Appeals; and its final judgment may be appealed to the Supreme Court. 

1. All cases in which the constitutionality or validity of any treaty, international or executive 

agreement, law, presidential decree, proclamation, order, instruction, ordinance, or regulation is in question.

• If the RTC, which has the power, declares the law as unconstitutional, the same has to be appealed directly to the SC. 
• It cannot pass through the CA because the SC has exclusive appellate jurisdiction regarding the matter.

2. All cases involving the legality of any tax, impost, assessment, or toll, or any penalty imposed in relation thereto.

• This is related to the legality of tax cases – whether a tax or tax penalty is legal or not. However, whatever decision the lower court gives, it has to be appealed directly to the SC.

3. All cases in which the jurisdiction of any lower court is in issue.

• If RTC or the MTC says it has jurisdiction or it has no jurisdiction over a case. The aggrieved party, it if wants to raise that issue, it must go to the SC. 
• When the issue is purely jurisdiction, the SC shall have exclusive appellate jurisdiction.

4. All criminal cases in which the penalty imposed is reclusion perpetua or higher. 

5. All cases in which only an error or question of law is involved.

• There is a question of law when the doubt or difference arises as to what the law is on a certain set of facts. 
• There is a question of fact when the doubt or difference arises as to the truth or falsehood of the alleged facts.
• Ex: 
• Where the question is whether or not the debtor has paid the debt, the issue is one of fact. 
• Where the question is whether or not the manner of payment is of the type which produces the legal effect of extinguishing the obligation, the issue becomes one of law.
• Also, when under the set of facts the issue is whether or not the law on double sales applies, there is a question of law.
• When the issue involves a review of the evidence, it involves a question of fact because evidence, as defined, is the means, sanctioned by the rules, of ascertaining in a judicial proceeding the truth respecting a matter of fact.

Q: In an action for declaration of nullity of marriage the basis is psychological incapacity. The RTC/Family Court dismissed the case finding that there was no psychological incapacity. If the plaintiff wants to appeal from that judgment, can she appeal directly to the SC? Is it a question of fact or law?

No. The appeal should be to the CA. The issue raised is a question of fact because there is need to review the evidence to resolve it. Suppose the court nullified the marriage on ground of impotence and the defendant wants to appeal because he wants to raise the issue whether or not impotence is a ground for declaration of nullity of marriage this would be a question of law because there is no need for review of the evidence to resolve it. So appeal is to the SC.

OTHER CONSTITUTIONAL PROVISIONS DEALING WITH THE JURISDICTION OF THE SUPREME COURT

1. Review on Constitutional Commissions

(Article IX, Section 7(a), 1987 Constitution)

Each Commission shall decide by a majority vote x x x. Unless otherwise provided by this Constitution or by law, any decision, order, or ruling of each Commission may be brought to the Supreme Court on certiorari by the aggrieved party within thirty days from receipt of a copy thereof.

• The COMELEC, COA and the CSC act also as courts of justice. They have powers to decide certain cases within their jurisdiction. 
• COMELEC ー Election cases
• COA ー claims against the government
• CSC ー eligibility or removal from government service of an appointive employee
• Any decision, order or ruling of these commissions may be brought to the SC on certiorari, etc. The decisions of the constitutional commissions are reviewable by the SC. 
• However, Congress amended the Judiciary Law, particularly Section 9 on the jurisdiction of the CA, by now making decisions of the CSC no longer appealable to the SC directly but appealable to the CA. 
• Based on the present law, out of the three constitutional commissions, the only ones whose decisions are appealable directly to the SC are those of the COMELEC and the COA 

Q: Under the Constitution, decisions of the constitutional commissions are appealable to the SC. What is the basis for Congress to pass such a law where a decision of a constitutional body (CSC) is reviewable by a non-constitutional body? Does Congress have the power to change that by making it appealable to the CA? 

Yes. The provision says: “Unless otherwise provided by this Constitution or by law..” Meaning, the decisions are appealable to the SC unless otherwise provided by law. The Constitution itself gave Congress the power to change it.

2. SC as Presidential Tribunal

(Article VII, Section 4(7), 1987 Constitution)

The Supreme Court, sitting en banc, shall be the sole judge of all contests relating to the election, returns, and qualifications of the President or Vice-President, and may promulgate its rules for the purpose.

• If there is an electoral protest for the President and Vice-President, the matter is not to be decided by the COMELEC but by the SC acting as the Presidential Electoral Tribunal.

3. Judicial Review of Presidential Proclamation of Martial or Suspension of the Privilege of the Writ of Habeas Corpus

(Article VII, Section 18(3), 1987 Constitution)

The Supreme Court may review, in an appropriate proceeding filed by any citizen, the sufficiency of the factual basis of the proclamation of martial law or the suspension of the privilege of the writ or the extension thereof, and must promulgate its decision thereon within thirty days from its filing.

• Commander-in-Chief Clause
• The SC, in an appropriate proceeding filed by any citizen review the sufficiency of the factual basis of the proclamation of martial law. 
• The SC can inquire into the basis on why martial law is declared.
• This is intended to prevent the Supreme Court from invoking the Political Question doctrine laid down in many earlier cases that it is the prerogative of the President to determine, at his discretion, the sufficiency of the factual basis of the proclamation of martial law or the suspension of the privilege of the writ or the extension thereof.

Congress and Jurisdiction of the SC

(Article VIII, Section 2, 1987 Constitution)

The Congress shall have the power to define, prescribe, and apportion the jurisdiction of the various courts but may not deprive the Supreme Court of its jurisdiction over cases enumerated in Section 5 hereof. 

• Congress may change or even remove the jurisdiction of the RTC or CA. 
• The law can change them because jurisdiction over the subject matter is conferred by law. 
• However, Congress does not have the power to lessen or deprive the Supreme Court of its jurisdiction under Section 5, Article VIII.

(Article VI, Section 30 1987 Constitution)

No law shall be passed increasing the appellate jurisdiction of the Supreme Court as provided in this Constitution without its advice and concurrence.”

• Congress cannot lessen but it can increase the SC’s powers and jurisdiction, provided it is with the latter's advice and concurrence.

The Supreme Court is not a Trier of Facts

• The SC is not a trier of facts which means that passing upon a factual issue is not within the province of the Court.
• The findings of facts of the Court of Appeals are not generally reviewable by the SC. Also, factual findings of the trial court, particularly when affirmed by the Court of Appeals, are generally binding on the Court.
• It is not the function of the SC to determine the weight of the evidence supporting the assailed decision. 
• However, factual issues may be delved into and resolved where the findings and conclusions of the trial court or the quasi-judicial bodies are frontally inconsistent with the findings of the CA.

Exceptions

1. when the findings are grounded entirely on speculation, surmises or conjectures;
2. when the inference made is manifestly mistaken, absurd or impossible;
3. when there is grave abuse of discretion;
4. when the judgment is based on a misapprehension of facts;
5. when the findings of  facts are conflicting;
6. when in making its findings the CA went beyond the issues of the case, or its findings are contrary to the admissions of both appellant and appellee;
7. when the findings are contrary to the trial court;
8. when the findings are conclusions without citation of specific evidence on which they are based;
9. when the facts set forth in the petition, as well as in the petitioner’s main and reply briefs, are not disputed by the respondent;
10. when the findings of fact are premised on the supposed absence of evidence and contradicted by the evidence on record; and
11. when the CA manifestly overlooked certain relevant facts not disputed by the parties, which, if properly considered, could justify a different conclusion.

2.     Jurisdiction of the Court of Appeals

Brief History of the Court of Appeals

• The jurisdiction of the CA is now governed by BP 129 or the Judiciary Reorganization Act of 1980.  BP 129 was passed in 1983 by the former Batasang Pambansa which practically abolished all the regular courts at that time, and also the special courts except the SC which cannot be abolished by Congress. The Court of Tax Appeals which was likewise not affected. In lieu of these, other courts were created. 
• The constitutionality of BP 129 was challenged as violative of the security of tenure of the judges. Its constitutionality was sustained in the case of Dela Llana v. Alba, 112 SCRA 294. 
• The CA is composed of over 69 justices after new divisions were created, pursuant to RA 8246.
• They decide cases by a division of three. They sit en banc only for administrative matters not to decide a case as it would be impractical considering their number. 
• Before BP 129, the court was also called the “Court of Appeals,” the counterpart of the present CA, though the CA now is different and more powerful than the old one. 
• BP 129 abolished the old CA and created another court which was called the Intermediate Appellate Court (IAC). (1983 ー1986)
• After the EDSA Revolution, President Aquino, pursuant to her law-making powers, issued E.O. No. 33 amending the Judiciary Law and changed the name of IAC to CA (referring to the jurisdiction of the IAC). Many people thought that the CA of President Aquino under E.O. #33 is actually the IAC under another name only, but in a case decided by the SC, reported in In Re: Letter of Associate Justuce Reynato S. Puno – 210 SCRA 589, the Court held:
• It is the holding of the Court that the present Court of Appeals is a new entity, different and distinct from the Court of Appeals or the Intermediate Appellate Court existing prior to Executive Order No. 33, for it was created in the wake of the massive reorganization launched by the revolutionary government of Corazon C. Aquino in the aftermath of the people power (EDSA) revolution in 1986.
• Section 5 of EO 33 also amended Sec. 9 of BP 129. In February 1995, it was amended again by RA 7902, known as “The Act expanding the jurisdiction of the CA.”
• RA 7902 restored the power of the CA to try cases and conduct hearings, receive evidence, and perform any and all acts necessary to resolve factual issues raised in cases falling within the original and appellate jurisdiction, including the power to grant new trials or further proceedings (without limiting the motion for new trial based on newly discovered evidence). Trials or hearings in the CA must be continuous and completed within 3 months unless extended by the Chief Justice.

ORIGINAL JURISDICTION OF THE COURT OF APPEALS

Original Concurrent

(Section 9(1), BP 129)

Original jurisdiction to issue writs of mandamus, prohibition, certiorari, habeas corpus, and quo warranto, and auxiliary writs or processes whether or not in aid of its appellate jurisdiction.

• The cases where its original jurisdiction is concurrent with the SC are petitions for the issuance of writs of certiorari, prohibition, mandamus against the following:
• the CSC; 
• Central Board of Assessment Appeals;
• NLRC or the Secretary of Labor under the Labor Code.
• Quasi-judicial agencies;
• RTC.
• Concurrent with the SC and RTC are those involving habeas corpus, quo warranto, and writs of certiorari, prohibition, and mandamus against inferior courts and bodies.

Ex: A petition for mandamus against the MTC of Cebu City can be filed with the SC, CA, or RTC although the policy of the Supreme Court is that it should be filed with the RTC based on the hierarchy of the courts.

Q: Being concurrent, what will happen if such a case is filed simultaneously in the CA and SC?

The consequence is found in Section 17 of the Interim Rules. In other words, the Interim Rules are still intact.

Interim Rules, Sec. 17. Petitions for writs of certiorari, etc. 

No petition for certiorari, mandamus, prohibition, habeas corpus or quo warranto may be filed in the IAC if another similar petition has been filed or is still pending in the SC. Nor may such petition be filed in the SC if a similar petition has been filed or is still pending in the IAC, unless it is to review the action taken by the IAC on the petition filed with it. A violation of this rule shall constitute contempt of court and shall be a cause for the summary dismissal of both petitions, without prejudice to the taking of appropriate action against the counsel or party concerned.

Original Exclusive

(Section 9(2), BP 129)

“Exclusive” jurisdiction over actions for annulment of judgments of Regional Trial Courts;

Q:  Are Actions for annulment of judgments of RTC similar to an appeal? Is this the same as appealing the decision of the RTC to the CA?

No, because in appeal, you are invoking the appellate jurisdiction of the CA. In Sec. 9(2) of BP 129, it is not appellate but original jurisdiction. Meaning, you are filing an action before the CA for the first time, and the nature of the action is to annul a judgment of the RTC.

APPELLATE JURISDICTION OF THE COURT OF APPEALS

Appellate

(Section 9(3), BP 129)

Exclusive appellate jurisdiction over all final judgments, decisions, resolutions, orders or awards of the RTCs and quasi-judicial agencies, instrumentalities, boards or commissions, including the Securities and 

Exchange Commission, the Social Security Commission, the Employees Compensation Commission and the Civil Service Commission, except those falling within the appellate jurisdiction of the SC in accordance with the Constitution, the Labor Code of the Philippines under PD 442, as amended, the provisions of this Act, and of subparagraph (1) of the third paragraph and subparagraph (4) of the fourth paragraph of Sec. 17 of the 

Judiciary Act of 1948.

• The appellate jurisdiction of the CA is exclusive.
• CA is a powerful court because it has exclusive appellate jurisdiction over all final judgments, decisions, resolution, orders or awards of RTCs. 
• General Rule: If the RTC, anywhere in the country renders a decision and you want to appeal, whether civil or criminal, chances are it will go the to CA.
• The law says “and quasi-judicial agencies, instrumentalities, boards or commissions…” Not only decisions of the RTC but also of quasi-judicial agencies or bodies, also called administrative bodies.
• Administrative bodies are actually part of the executive branch but they act just like courts of justice. 
• The amendments by RA 7902 is even more specific by adding this phrase, “including the SEC, SSS, the Employees Compensation commission and the Civil Service Commission (CSC).”
• Before this law was passed, under the Constitution, decisions of the CSC are appealed to the SC together with the COMELEC and the COA. But with the passage of RA 7902, the appeal from the CSC has been transferred to the CA, so what is left behind in the Constitution are the COMELEC and the COA.
• Purpose: To unburden the SC with many cases. 
• The phrase “except those falling within the appellate jurisdiction of the Supreme Court…”means all cases should be appealed to the CA except those which belong to the SC under the Constitution.
• For the phrase “except those falling under the Labor Code of the Philippines”:
• A labor case is not supposed to be filed in court but with a quasi-judicial agency known as the NLRC, starting in the local level – from the Labor Arbiter. The decisions of the Labor Arbiter.

Q: Is the decision of the NLRC appealable before the CA because it is also a quasi-judicial agency and under the law, all decisions of quasi-judicial agencies are supposed to be appealed to the CA.

No. The decision of the NLRC is an exception.

NLRC decisions cannot be appealed to the CA and the only way to elevate it is to the SC by what we call certiorari, not appeal.

Also, decisions of the Secretary of Labor, under the Labor Code are not reviewable by the CA, but they are reviewable directly by the SC.

• There is the phrase,  “the provisions of this Act, and of subparagraph (1) of the third paragraph and subparagraph (4) of the fourth paragraph of Section 17 of the Judiciary Act of 1948.” 
• The new Judiciary Law still makes some reference to the old law. The entire 1948 Judiciary Law has not been totally repealed. Some provisions are still intact because of the reference. 
• Subparagraph 4 of the fourth paragraph of Section 17 refers to appeal from the RTC on pure legal question which should be filed with the SC.
• The same thing when the issue is on the constitutionality of a treaty, law, legality of tax, when the jurisdiction of the lower court is in issue, as explained here in this paragraph of the Judiciary Act of 1948,
• If the appeal is 100% constitutional issue, jurisdictional or legality issue – appeal is to the SC under the Constitution. 
• If it is mixed with questions of fact, CA. 

Q: What is this subparagraph 1 of the third paragraph? 

It only applies to criminal cases. 

Example: A person is sentenced to reclusion perpetua, his co-accused is sentenced to reclusion temporal or prison mayor, and all of them will appeal, all of them should go to the SC. Otherwise, you will be splitting the appeal into two parts. 

Q: Suppose there are questions of fact, or it is an appeal on questions of fact and questions of law? 

Under the 1948 Judiciary Law, you cannot appeal directly to the SC. You must appeal to the CA.

Exclusive Appellate Jurisdiction

• Exclusive appellate jurisdiction by way of ordinary appeal from the RTC and the Family Courts.
• Exclusive appellate jurisdiction by way of petition for review from the RTC rendered by the RTC in the exercise of its appellate jurisdiction.
• Exclusive appellate jurisdiction by way of petition for review from the decisions, resolutions or orders or awards of the CSC, Central Board of Assessment Appeals and other bodies mentioned in Rule 43 and of the Office of the Ombudsman in administrative disciplinary cases.
• Under RA No. 9282, the judgments and final orders of the Court of Tax Appeals are no longer appealable by way of petition for review to the CA. 
• Judgments of the CTA rendered en banc are appealable to the SC by way of Rule 45.
• Exclusive appellate jurisdiction over decisions of MTCs in cadastral or land registration cases pursuant to its delegated jurisdiction. 
• This is because decisions of MTCs in these cases cases are appealable in the same manner as decisions of RTCs.

Power to Try and Conduct Hearings

(Section 9(4), BP 129)

The Court of Appeals shall have the power to try cases and conduct hearings, receive 

evidence and perform any and all acts necessary to resolve factual issues raised in cases falling within its original and appellate jurisdiction, including the power to grant and 

conduct new trials or further proceedings. Trials or hearings in the CA must be continuous and must be completed within three (3) months unless extended by the Chief Justice. 

• Even if the CA is not a trial court, under the law it has the power to try cases and conduct hearings, receive evidence and perform any and all acts necessary to resolve factual issues in cases falling within its original and appellate jurisdiction, including the power to grant and conduct new trials or further proceedings.
• The CA may pass upon factual issues as when a petition for certiorari is filed before it or in petitions for writ of amparo or habeas corpus data or in case of actions to annul judgment of the RTC over which the CA has original jurisdiction 
• CA is a unique court. Aside from being an appellate court, it also acts as a trial court. 
• It may receive evidence but only those evidence which were overlooked by the trial court. It can order a new trial or conduct a new trial itself. The CA may pass upon factual issues. 

Q: If an issue of fact is tried before the RTC, can I always ask the CA to allow me to present evidence? Does it mean to say now that since the CA is a very powerful court, it can take the place of the RTC?

The power of the CA to receive evidence refers only to incidental facts which were not 100% touched upon, or matters which were simply overlooked by the trial court. 

You cannot opt not to present evidence before the RTC. It only refers to incidental facts. “Evidence necessary in regards to factual issues raised in cases falling within the Appellate Court’s original and appellate jurisdiction contemplates ‘incidental’ facts which were not touched upon, or fully heard by the trial or respondent Court. The law could not have intended that the Appellate Court would hold an original and full trial of a main factual issue in a case, which properly pertains to Trial Courts.” (Linger and Fisher v. IAC)

3.     Jurisdiction of the RTCs (include RA 11576)

Q: How many RTC’s are there in the Philippines? 

BP 129 Section 13 (1) Creation of Regional Trial Courts – There are hereby created thirteen (13) Regional Trial Courts, one for each of the following regions: x x

• The Judiciary law has divided the country into 13 areas called JUDICIAL REGIONS. 
• From the 1st to the 12th, the 13th is actually in the National Capital Region (NCR), Metro Manila. 
• Every division is divided into branches. 
• Every RTC judge is appointed to a region which shall be his permanent station, and his appointment states the branch of the court and seat to which he shall be originally assigned. 
• However, the SC may assign temporarily an RTC judge to another region as public interest may require, provided that such temporary assignment shall not last longer than 6 months without the consent of the RTC judge concerned. 
• The SC shall define the territory over which a branch of the RTC shall exercise his authority. The law provides:
• BP 129, Section 18. Authority to define territory appurtenant to each branch – The Supreme Court shall define the territory over which a branch of the Regional Trial Court shall exercise its authority. The territory thus defined shall be deemed to be the territorial area of the branch concerned for purposes of determining the venue of all suits, proceedings or actions, whether civil or criminal, as well as determining the Metropolitan Trial Courts, Municipal Trial Courts, and Municipal Circuit Trial Courts over which the said branch may exercise appellate jurisdiction. The power herein granted shall be exercised with a view to making the courts readily accessible to the people of the different parts of the region and making the attendance of litigants and witness as inexpensive as possible.
• RTC Puerto Princesa is found in the 4th Judicial Region, which includes Batangas, Cavite, Laguna, Marinduque, Occidental Mindoro, Oriental Mindoro Quezon, Rizal and Romblon province, its territorial area is not the entire region, (4th Judicial Region), it is limited to Puerto Princesa City only because it depends on the territory as defined by the SC.
• The law says, the SC has the power to define the area of its branch for purposes of supervising that area and the MTC there. As early as 1983, the SC has already come out with the administrative order defining the area of responsibility of each branch throughout the Philippines.
• Interim Rules, Sec. 2. Territorial Jurisdiction of Courts. - 
• a) MetTCs, MTCs and MCTCs shall exercise their jurisdiction in the city, municipality or circuit for which the judge thereof is appointed or designated. 
• b) A Regional Trial Court shall exercise its jurisdiction within the area defined by the SC as the territory over which the particular branch concerned shall exercise its authority, in accordance with Sec. 18 of BP 129.

Exclusive Original Jurisdiction:

1. In all civil actions in which the subject of the litigation is incapable of pecuniary estimation;
• Claim cannot be quantified to money; e.g. action for specific performance.
2. In all civil actions which involve the title to, or possession of, real property, or any interest therein, where the assessed value of the property involved exceeds 20K or for civil actions in Metro Manila, where such the value exceeds Fifty thousand pesos 50K except actions for forcible entry into and unlawful detainer of lands or buildings, original jurisdiction over which is conferred upon MeTC, MTC, MCTC;
• Applicable to real actions to recover real property. 
3. In all actions in admiralty and maritime jurisdiction where the demand or claim exceeds 300K or, in Metro Manila, where such demand or claim exceeds 400K;
4. In all matters of probate, both testate and intestate, where the gross value of the estate exceeds 300K or, in probate matters in Metro Manila, where such gross value exceeds 400K;
5. In all actions involving the contract of marriage and marital relations;
6. In all cases not within the exclusive jurisdiction of any court, tribunal, person or body exercising jurisdiction or any court, tribunal, person or body exercising judicial or quasi-judicial functions; 
• Catch-all provision
7. In all civil actions and special proceedings falling within the exclusive original jurisdiction of a Juvenile and Domestic Relations Court and of the Courts of Agrarian Relations as now provided by law; and
8. In all other cases in which the demand, exclusive of interest, damages of whatever kind, attorney's fees, litigation expenses, and costs or the value of the property in controversy exceeds 300K or, in Metro Manila 400K). 
• If claim for damages be the principal cause of action, then it is made the basis for calculating the value. 
• If damages is but incidental to another cause of action, then it is excluded from the calculation

Concurrent Original Jurisdiction:

1. In the issuance of writs of certiorari, prohibition, mandamus, quo warranto, habeas corpus and injunction which may be enforced in any part of their respective regions; and
2. In actions affecting ambassadors and other public ministers and consuls.

RA No 11576 has amended the jurisdictional limits. However, said law has only been effective after 30 June 2021.

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Exclusive Original Jurisdiction:

1. In all civil actions in which the subject of the litigation is incapable of pecuniary estimation;

Q: What does incapable of pecuniary estimation mean?

• In an action incapable of pecuniary estimation, the basic issue is one other than the recovery of a sum of money. 
• If ever there is a claim for money, it should only be incidental to the main issue.
• Where the action is principally the recovery of a sum of money, the action is one capable of pecuniary estimation and jurisdiction would then depend on the amount of the claim exclusive of interest, damages of whatever kind, attorneys fees, litigation expenses and costs. 
• The basic issue in an action incapable of pecuniary estimation is one other than the recovery of money. In this kind of action the money claim is merely incidental.

Q: How to determine whether the action is capable or incapable of pecuniary estimation? 

• In determining whether an action is one the subject matter of which is not capable of pecuniary estimation, this Court has adopted the criterion of first ascertaining the nature of the principal action or remedy sought. 
• If it is primarily for the recovery of a sum of money, the claim is considered capable of pecuniary estimation and whether jurisdiction is in the MTCs or the CFIs would depend on the amount of the claim. 
• However, where the basic issue is something other than the right to recover a sum of money, where the money claim is purely incidental to, or a consequence of, the principal relief sought, this Court has considered such actions as cases where the subject of the litigation may not be estimated in terms of money, and are cognizable exclusively by the CFI.
• Examples of actions incapable of pecuniary estimation are: 
• specific performance
• support
• foreclosure of mortgage
• annulment of judgment
• questioning the validity of a mortgage
• annulling a deed of sale or conveyance
• recover the price paid
• rescission which is a counterpart of specific performance
• complaint for expropriation
• action seeking to annul a resolution of a government-owned and controlled corporation
• action for injunction
• action to annul a Deed of Declaration of Heirs and for a partition of land with an assessed value of P5,000.00, where the partition aspect is only incidental to the action for annulment
• action for partition of a real property located in Taytay Rizal and with an assessed value of P20,000.00, the resolution of which involves the determination of hereditary rights
• specific performance to compel the defendant to execute a deed of conveyance covering a parcel of land with an assessed value of P19,000.00, because the main issue is whether or not there is a right to compel specific performance 
• Such ruling was, however, modified in Go vs. UCPB, GR No. 156182 Nov. 11, 2004 where the court declared the following as real actions: 
• judicial foreclosure of real estate mortgage;
• actions to annul real estate mortgage; 
• for the reason that a real estate mortgage is a real right as well as a real property. 
• an action to cancel or annul a real estate mortgage necessarily affects title to the real property, hence a real action and jurisdiction is determined by the assessed value of the property. 
• A complaint for expropriation is incapable of pecuniary estimation 
• The amount of damages that may be claimed in addition to the prayer for specific performance is not determinative of jurisdiction. 
• Thus, an action for specific performance and damages of P200,000.00 is cognizable by the RTC even if the amount of damages sought to be recovered is within the jurisdiction of the MTC.
• If the demand is in alternative, as in an action to compel the defendant to deliver the house by completing its construction or to pay the sum of P644.31, the action is one that is capable of pecuniary estimation.
• Thus an action for specific performance or in a the alternative, for damages in the amount of P180,000.00 is one capable of pecuniary estimation. Here, the amount of damages is determinative of jurisdiction.
• If as gleaned from the complaint, the principal relief sought by the complaint is for the court to issue an injunction against the adverse party and his representatives to permanently enjoin them from preventing the survey of the subject land, the complaint is not a possessory action but one for injunction. As such, the subject matter of litigation is incapable of pecuniary estimation and properly cognizable exclusively by the RTC.
• An action for replevin of a motorcycle valued at P150,000.00 is capable of pecuniary estimation. The basis of jurisdiction is the value of the personal property sought to be recovered. The amount of P150,000.00 falls within the jurisdiction of the MTC. 
• An action for interpleader is capable of pecuniary estimation. If the subject of interpleader is real property, then the jurisdictional amount is determined by the assessed value of the land. If it be personal property, then the value of the property. Hence, an action of interpleader to determine who between the defendants is entitled to receive the amount of P190,000.00 from the plaintiff is within the jurisdiction of the MTC.

2. In all civil actions which involve the title to, or possession of, real property or any interest therein, where the assessed value of the property involved exceeds P20,000 or for civil actions in Metro Manila, where such value exceeds P50,000 except actions for forcible entry into and unlawful detainer of lands and buildings; original jurisdiction over which is conferred upon the Metropolitan Trial Courts, Municipal Circuit Trial Courts;

So in all real actions outside of forcible entry and unlawful detainer, jurisdiction is determined by the assessed value of the real property subject thereof.

Q: What is a real action?

• It is one affecting title to or possession of real property, or interest therein. (Sec. 1, Rule 4) 
• Examples provided the assessed value of the property exceeds P20,000.00:
• accion publiciana (an action to recover possession of real property)
• accion reinvidicatoria (action to recover ownership of real property)
• quieting of title
• For a lesser value, MTC has jurisdiction.
• MTCs have jurisdiction over accion publiciana when the value of the property is P20,000 or less. 
• In forcible entry and unlawful detainer, jurisdiction lies with the MTC regardless of the assessed value.
• In Metro Manila, the value is P50,000. 

3. In all civil actions in admiralty and maritime jurisdiction where the demand or claim exceeds Three Hundred Thousand pesos (P300,00.00) or, in Metro Manila, where such demand or claim exceeds Four Hundred Thousand pesos (P400,000.00)[now, PhP 400,000].

• Example:
• The shipper will ship to you goods involving a common carrier and while in transit, the goods are lost or they are totally damaged.
• You would like to file a claim or a case against the carrier, what kind of a case is it? That is an admiralty or maritime case. 
• Q: In which court will you file it? 
• A: It depends on how much is your claim. 
• If your claim of the damaged or lost cargo exceeds P300,000, then, RTC; if it is P300,000 or less, MTC.
• In Metro Manila, the jurisdictional amount is higher – it should be over P400,000.

RA 7691, Sec. 5. 

After five (5) years from the effectivity of this Act, the jurisdictional amounts mentioned in Sec. 19(3), (4), and (8); and Sec. 33(1) of Batas Pambansa Blg. 129 as amended by this Act, shall be adjusted to Two hundred thousand pesos (P200,000.00). Five (5) years thereafter, such jurisdictional amounts shall be adjusted further to Three hundred thousand pesos (P300,000.00): Provided, however, That in the case of Metro Manila, the abovementioned jurisdictional amounts shall be adjusted after five (5) years from the effectivity of this Act to Four hundred thousand pesos (P400,000,00).

4. In all matters of probate, both testate and intestate, where the gross value of the estate exceeds Three Hundred Thousand pesos (P300,000.00) or, in probate matters in Metro Manila, where such gross value exceeds Four Hundred Thousand pesos (P400,000.00).

• In the subject of Wills and Succession, when a person dies, his estate, his property will be settled for the benefit of his creditors and heirs. That is what you call either as testate or intestate proceedings depending on whether the deceased left a will or none. 
• If there are debts due the decedent, thus, payable by his/her estate, settlement would mean liquidation, which includes inventory of all the assets and obligations payable, payment of the debts, then distribution of the residue to the heirs. 
• This is done by the court thru an administrator appointed by it or thru the executor appointed by the decedent. 
• Q: Where should the estate of the deceased person be settled, RTC or MTC? 
• A: It depends on how much is the gross value of his estate.
• If it exceeds P300,000, RTC. 
• If it is P300,000 or less, it should be with the MTC. 
• In Metro Manila again, the gross should be more than P400,000.
• The jurisdiction of the court as a probate or intestate court relates only to matters having to do with the settlement of the estate and probate of the will of the decedent but does not extend to the determination of questions of ownership that arise during the proceedings.

5. In all actions involving the contract of marriage and marital relations. 

• Most of these cases are under the Family Code and now fall under the jurisdiction of family courts (RA 8369, The Family Courts Act of 1997). 
• But because family courts have not yet been constituted, the SC has designated RTCs to take cognizance of such cases. 
• Q: What are the possible actions which you can imagine involving the contract of marriage and marital relations?
• Annulment of marriage, 
• legal separation, 
• declaration of nullity, 
• dissolution of the absolute community of husband and wife, 
• action for support

7. In all civil actions and special proceedings falling within the exclusive original jurisdiction of a Juvenile and Domestic Relations Court and of the Court of Agrarian Relations as now provided by law; 

• Before BP 129 or before 1980, there were special courts existing. Among these courts were the so called Juvenile and Domestic Relations Courts (JDRC). 
• Then you have the Court of Agrarian Relations (CAR) which tried cases involving tenancy, agricultural lessor, agricultural lessee, agricultural lands. 
• When BP 129 was enacted, the CAR and the JDRCs were abolished together with the other courts created by law. Cases which they used to handle were automatically transferred to the RTC. That was after BP 129 took effect.
• Q: What were the cases which were usually falling within the original jurisdiction of the former JDRC?
  • support filed by the child against his father
  • compulsory recognition
  • custody of children
  • adoption proceedings
• Under BP 129, all of these are now within the jurisdiction of RTC. 
• However, this has been amended again by RA 8369 (Family Courts Act of 1997) and these cases are now under the jurisdiction of the Family Courts.
• As regards the law transferring the jurisdiction of the CAR to the RTC, it became partially obsolete with the enactment of the Comprehensive Agrarian Reform Law (CARL) or RA 6657 (June 15, 1988). 
• Under the CARL, all agrarian disputes between landlord and tenant, lessor and lessee were transferred to the DAR particularly the DAR Adjudication Board (DARAB), making them quasi-judicial cases. 
• So, from CAR to RTC, from RTC to DARAB.
• The RTC has NO jurisdiction, except in the following cases:
• petitions for the determination of just compensation to landowners; and 
• prosecution of criminal offenses under said Act
• Q: If you are a landowner and your agricultural land is placed under the CARP coverage, the government will fix the payment for you. The trouble is that you did not agree on the amount of payment. You want to contest the amount of compensation payable, in which court will you file your action? 
• A: RTC and you ask for higher compensation.

8. In all cases in which the demand, exclusive of interest, damages of whatever kind, attorney’s fees, litigation expenses, and costs or the value of the property in controversy exceeds Three Hundred Thousand pesos (P300,000.00) or, in such other cases in Metro Manila, where the demand, exclusive of the above-mentioned items exceeds Four Hundred Thousand pesos (P400,000.00).

• The best example is money claim.
• Most cases which go to court now are money claims – an action to collect sum of money. 
• Q: Unpaid loan – you would like to collect an unpaid loan of your debtor. Where will you file your case? 
• A: It depends on how much are you collecting. 
• If it is over P300,000 outside Metro Manila – RTC, in Metro Manila, – P400,000. 
• If the amount that you are collecting is only P300,000 or less obviously, you file your case in the MTC.
• If the value of the claim is > P300,000 – RTC 
• If the value of the claim is = or < P300,000 – MTC
• Q: Suppose the principal amount that you borrowed from me is P300,000, the interest is P30,000. And you are collecting P10,000 for moral damages, another P10,000 for expense of litigation, etc. So my total claim is P350,000. Where will I file the case? 
• A: MTC. In determining the jurisdictional limit of P300,000, do not include the interest, damages, attorney’s fees, etc. So you deduct those from the principal claim even if you put them in your complaint because the law says, “xxx exclusive of interest, damages of whatever kind, attorney’s fees, litigation expenses, and costs xxx.” 
• Q: What are litigation expenses and costs? 
• A: Costs are not the same as attorney’s fees and litigation expenses. 
• Actually, attorney’s fees and litigation expenses are part of damages.
• Costs are governed by Rule 141, while attorney’s fees and litigation expenses are governed by the Civil Code.

ACTIONS PURELY FOR DAMAGES

• Suppose the action is purely for damages, like breach of contract of carriage. Instead of bringing you to your destination, you ended up in the hospital. You now sue the common carrier for damages and your claim is P1 million for injuries, moral, exemplary, etc. Where will you file the case? 
• This question has been clarified by SC Circular No. 09-94: “Guidelines in the Implementation of RA 7691 Extending the Jurisdiction of the MTCs” where the SC said that the provision excluding damages applies only if the damages are INCIDENTAL to the action. 
• If the main cause of action is 100% damages, you include it in determining tire P300,000 jurisdictional limit of the MTC,
• Q: Ms. Pastor rode on a PAL fight. The plane crashed but she survived. She claims for damages for breach of contract of carriage amounting to P1 million. Where will she file her case?
• RTC because the amount of the claim for damages exceeded P300,000. 
• Since the case is purely for damages, it is included in determining the jurisdiction of the court. 
• The rule is, you only exclude the damages if it is a secondary claim. 
• But if damages is the primary or only claim, you determine whether the total claim for damages is above P300,000, or equal to or less than P300,000. 
• The SC said in this Circular, “the exclusive damages of whatever kind” in determining the jurisdiction under Section 19 paragraph [8] applies to cases where the damages are merely incidental to or a consequence of the main cause of action. However, if the claim for damages is the main cause of action, the amount of such claim should be considered in determining the jurisdiction.
• Q: P will file a case against D to recover a piece of land worth P20,000.00 only. But her claim for damages exceeds P300,000. In what court will P file a civil case where she wants to recover a piece of land with value of only P20,000? 
• A: MTC because of paragraph [2]. As regards the damages of P300,000.00, MTC still has jurisdiction because such damages being incidental, is not included in determining the jurisdiction of the RTC.
• Q: Now, the law says, “exclusive of interest, damages of whatever kind, attorney’s fees, litigation expenses, and costs or THE VALUE OF THE PROPERTY IN CONTROVERSY exceeds P300,000….”  What is the property in controversy? 
• A: Obviously here, the property is PERSONAL PROPERTY not real. If the property sought to be recovered is real, apply paragraph [2] of Section 19 on recovery of real property. 
• Q: You want to recover your car which your friend borrowed but did not return, which court has jurisdiction? 
• A: MTC if the value is P300,000.00 or less, and RTC, if over. 
• Q: Who shall determine the value or how should the value be determined? A: In determining the jurisdiction of the court, over the subject matter, the allegations in the complaint governs.

   Cases:  Ortigas and Co., Ltd Partenrship vs. Herrera, 120 SCRA 89

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.

The title of the action is not determinative on the court. 

• Just like the rule on contracts where the nature of the contract is not determined by the title but by stipulation. 
• “The factual allegations in the complaint seeking for the performance of an obligation of a written contract which is a matter clearly incapable of pecuniary estimation prevail over the designation of the complaint as one for the sum of money and damages.” 
• As may be seen from the foregoing enumeration, jurisdiction is determined:
• by the nature of the action; or
• by the value of the demand; or 
• by the value of the property involved. 

[6] In all cases not within the exclusive jurisdiction of any court, tribunal, person or body exercising judicial or quasi-judicial functions.

• Practically, this makes the RTC the universal catcher – what does not belong to any other court, belongs to the RTC. 
• That’s what this provision is saying. That is why, because of this, there are problems reaching the SC on jurisdiction – whether a case belongs to this, to the regular court or to a special quasi-judicial body. 

                 Sandoval vs. Caneba, 190 SCRA 77

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

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

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 291

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

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

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.

                 Lupangco, et al., vs. Court of Appeals, 160 SCRA 848

The Professional Regulation Commission issued Resolution No. 105, which prohibited examinees preparing for licensure examinations in accountancy from attending review classes or receiving any assistance from educational institutions, review centers, instructors, or others during the three days before each examination day.

A group of reviewees filed a complaint against the PRC in the Regional Trial Court to challenge the constitutionality of Resolution No. 105 and sought a preliminary injunction.

The RTC initially declared that it had jurisdiction over the case and granted the preliminary injunction. The PRC appealed the decision to the Court of Appeals, arguing that the RTC had no jurisdiction to review and enjoin the enforcement of its resolution.

The CA sided with the PRC and nullified the RTC's decision, stating that the PRC and RTC were co-equal bodies and could not control each other's actions.

Issue: WoN RTC has jurisdiction over the case. YES

The Supreme Court ruled in favor of the petitioners, asserting that the RTC had jurisdiction over the case.

There is no provision in Presidential Decree No. 223, creating the Professional Regulation Commission, that orders or resolutions of the Commission are appealable either to the Court of Appeals or to the Supreme Court. Consequently, this case, which was filed in order to enjoin the enforcement of a resolution of the respondent Professional Regulation Commission, should fall within the general jurisdiction of the Court of First Instance, now the Regional Trial Court. 

                 Bernardo vs. Caltex Phil. Inc. 216 SCRA 170

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 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.

4.     Jurisdiction of the Family Courts

1. Criminal cases where one or more of the accused is below eighteen (18) years of age but not less than nine (9) years of age or where one or more of the victims is a minor at the time of the commission of the offense: Provided, That if the minor is found guilty, the court shall promulgate sentence and ascertain any civil liability which the accused may have incurred.
• The sentence, however, shall be suspended without need of application pursuant to Presidential Decree No. 603, otherwise known as the "Child and Youth Welfare Code";
2. Petitions for guardianship, custody of children, habeas corpus in relation to the latter;
3. Petitions for adoption of children and the revocation thereof;
4. Complaints for annulment of marriage, declaration of nullity of marriage and those relating to marital status and property relations of husband and wife or those living together under different status and agreements, and petitions for dissolution of conjugal partnership of gains;
5. Petitions for support and/or acknowledgment;
6. Summary judicial proceedings brought under the provisions of Executive Order No. 209, otherwise known as the "Family Code of the Philippines";
7. Petitions for declaration of status of children as abandoned, dependent o neglected children, petitions for voluntary or involuntary commitment of children; the suspension, termination, or restoration of parental authority and other cases cognizable under Presidential Decree No. 603, Executive Order No. 56, (Series of 1986), and other related laws;
8. Petitions for the constitution of the family home;
9. Cases against minors cognizable under the Dangerous Drugs Act, as amended;
10. Violations of Republic Act No. 7610, otherwise known as the "Special Protection of Children Against Child Abuse, Exploitation and Discrimination Act," as amended by Republic Act No. 7658; and
11. Cases of domestic violence against:
1. Women - which are acts of gender based violence that results, or are likely to result in physical, sexual or psychological harm or suffering to women; and other forms of physical abuse such as battering or threats and coercion which violate a woman's personhood, integrity and freedom movement; and
2. Children - which include the commission of all forms of abuse, neglect, cruelty, exploitation, violence, and discrimination and all other conditions prejudicial to their development.

         Case:       People vs. Yadao, G.R. Nos. 162144-54, Nov. 13, 2012

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.

5.     Jurisdiction of the MTCs

Exclusive Original Jurisdiction 

1. Civil actions and probate proceedings, testate and intestate, including the grant of provisional remedies in proper cases, where the value of the personal property, estate, or amount of the demand does not exceed 300K or, in Metro Manila —400K exclusive of interest damages of whatever kind,attorney's fees, litigation expenses, and costs, the amount of which must be specifically alleged:
• Provided, That interest, damages of whatever kind, attorney's fees, litigation expenses, and costs shall be included in the determination of the filing fees: 
• Provided further, That where there are several claims or causes of actions between the same or different parties, embodied in the same complaint, the amount of the demand shall be the totality of the claims in all the causes of action, irrespective of whether the causes of action arose out of the same or different transactions.
2. Forcible entry and unlawful detainer.
3. All civil actions which involve title to, or possession of, real property, or any interest therein where the assessed value of the property or interest therein does not exceed 20K or, in civil actions in Metro Manila, where such assessed value does not exceed 50K exclusive of interest, damages of whatever kind, attorney's fees, litigation expenses and costs:
• Provided, That value of such property shall be determined by the assessed value of the adjacent lots. 

Delegated Jurisdiction

•  Cadastral or land registration cases covering lots

• where there is no controversy or opposition, or
• contested lots the value of which does not exceed P100K, such value to be ascertained by the affidavit of the claimant or by agreement of the respective claimants if there are more than one, or from the corresponding declaration of the real property.

Special Jurisdiction 

• In the absence of all the Regional Trial Judges in a province or city, any Metropolitan, Municipal, Municipal Circuit Trial Judge may hear and decide petitions for a writ of habeas corpus or applications for bail in criminal cases in the province or city where the absent Regional Trial Judges sit.

         Case:       Vda. De Barrera vs. Heirs of Legaspi, G.R. No. 174346, Sept. 12, 2008

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.