Jurisdiction Case Doctrines (Compilation)

Marjorie Castillo & Monica Cajucom SOLEMNIDAD M. BUAYA v. THE HONORABLE WENCESLAO M. POLO and the COUNTRY BANKERS INSURANCE CORPORATION Allegations in the complaint or information determine jurisdiction In Villanueva v. Ortiz, et al . (L-15344, May 30, 1960, 108 Phil, 493) this Court ruled that in order to determine the jurisdiction of the court in criminal cases, the complaint must be examined for the purpose of ascertaining whether or not the facts set out therein and the punishment provided for by law fall within the jurisdiction of the court where the complaint is filed. The jurisdiction of courts in criminal cases is determined by the allegations of the complaint or information, and not by the findings the court may make after the trial (People v. Mission, 87 Phil. 641). In re: Estafa Section 14(a), Rule 110 of the Revised Rules of Court provides: In all criminal — prosecutions the action shall be instituted and tried in the court of the municipality or province wherein the offense was committed or any of the essential elements thereof took place.

Besides, the crime of estafa is a continuing or transitory offense which may be prosecuted at the place where any of the essential elements of the crime took place. One of the essential elements of estafa is damage or prejudice to the offended party. The private respondent has its principal place of business and office at Manila. The failure of the petitioner to remit the insurance premiums she collected allegedly caused damage and prejudice to private respondent in Manila.

JURISDICTION Case Doctrines

ISIDRO PABLITO M. PALANA v. v.PEOPLE PEOPLE OF THE PHILIPPINES Law at the time of institution of the action determines jurisdiction in criminal actions It is hornbook doctrine that jurisdiction to try a criminal action is determined by the law in force at the time of the institution of the action and not during the arraignment of the accused. Prospective application The subsequent amendment of B.P. 129 by R.A. No. 7691, ―An Act Expanding the Jurisdiction of the Municipal Trial Courts, Municipal Circuit Trial Courts and the Metropolitan Trial Court‖ on June 15, 1994 cannot divest t he Regional Tri al Court of jurisdiction jurisdic tion over petitioner’s case. Where a court cour t has already obt ained and is exercising jurisdiction over a controversy, its jurisdiction to proceed to the final determination of the cause is not affected by new legislation placing jurisdiction over such proceedings in another tribunal unless the statute expressly provides, or is construed to the effect that it is intended to operate on actions pending before its enactment. Indeed, R.A. No. 7691 contains retroactive provisions. However, these only apply to civil cases that have not yet reached the pre-trial stage. In re: BP 22 In the present case, the fine imposable is P200,000.00 hence, the Regional Trial Court properly acquired jurisdiction over the case. The Metropolitan Trial Court could not acquire jurisdiction over the criminal action because its jurisdiction is only for offenses punishable with a fine of not more than P4,000.00.

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Marjorie Castillo & Monica Cajucom PEOPLE OF THE PHILIPPINES v. ALEJO TAROY y TARNATE Jurisdiction is where the offense was committed or where any of its essential ingredients took place Venue is jurisdictional in criminal cases. It can neither be waived nor subjected to stipulation. The right venue must exist as a matter of law. Thus, for territorial jurisdiction to attach, the criminal action must be instituted and tried in the proper court of the municipality, city, or province where the offense was committed or where any of its essential ingredients took place. In re: Case The Informations filed with the RTC of La Trinidad state that the crimes were committed in the victim and the offender’s house in City Limit, Tuding, Municipality of Itogon, Province of Benguet. This allegation conferred territorial jurisdiction over the subject offenses on the RTC of La Trinidad, Benguet. The testimonies of Mila and Des as well as the t he affidavit of arrest point to this fact. Clearly, Taroy’s uncorroborated assertion that the subject offenses took place in Baguio City is not entitled to belief. Besides, he admitted during the pre-trial in the case that it was the RTC of La Trinidad that had jurisdiction jurisdiction to hear the case. case. Taken altogether, that RTC’s jurisdiction to hear the case is beyond dispute.


Except in applications for bail, it is not necessary for the court to first acquire jurisdiction over the person of the accused to dismiss the case or grant other relief. Examples: 1) The outright dismissal of the case even before the court acquires jurisdiction over the person of the accused is authorized under Section 6(a), Rule 112 of the Revised Rules of Criminal Procedure and the Revised Rules on Summary Procedure (Sec. 12a). 2) In Allado vs. Diokno (232 SCRA 192), the case was dismissed on motion of the accused for lack of probable cause without the accused having been arrested. Accused submits to the jurisdiction of the court upon seeking affirmative relief In cases not involving the so-called special appearance, the general rule applies, i.e., the accused is deemed to have submitted himself to the jurisdiction of the court upon seeking affirmative relief. Notwithstanding this, there is no requirement for him to be in the custody of the law.

JOSE C. MIRANDA, ET. AL v. v.VIRGILIO VIRGILIO M. TULIAO

Custody of the law vs. Jurisdiction over the person Custody of the law is required before the court can act upon the application for bail, but is not required for the adjudication of other reliefs sought by the defendant where the mere application therefor constitutes a waiver of the defense of lack of jurisdiction over the person of the accused.

Jurisdiction over the person of the accused not required in motion to quash warrant of arrest and other relief; Exception Adjudication Adjudication of a motion to quash a warrant of arrest requires neither neither jurisdiction jurisdiction over the person of the accused, accused, nor custody of law over the body of the accused.

Custody of the law is accomplished either by arrest or voluntary surrender, while jurisdiction over the person of the accused is acquired upon his arrest or voluntary appearance. One can be under under the custody of the law but not yet subject to the jurisdiction of the court over his person, such as when a person arrested by virtue of a

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Marjorie Castillo & Monica Cajucom warrant files a motion before arraignment to quash the warrant. On the other hand, one can be subject to the jurisdiction of the court over his person, and yet not be in the custody of the law, such as when an accused escapes custody after his trial has commenced. Being in the custody of the law signifies restraint on the person, who is thereby deprived of his own will and liberty, binding him to become obedient to the will of the law. Custody of the law is literally custody over the body of the accused. It includes, but is not limited to, detention.

VENANCIO FIGUEROA v. v. PEOPLE PEOPLE OF THE PHILIPPINES Jurisdiction can be raised at any stage of the proceedings; Exception The general rule should, however, be, as it has always been, that the issue of jurisdiction may be raised at any stage of the proceedings, even on appeal, and is not lost by waiver or by estoppel. Estoppel by laches, to bar a litigant from asserting the court’s absence or lack of jurisdiction, only supervenes in exceptional cases similar to the factual milieu of Tijam v. Sibonghanoy. Indeed, the fact that a person attempts to invoke unauthorized jurisdiction of a court does not estop him from thereafter challenging its jurisdiction over the subject matter, since such jurisdiction must arise by law and not by mere consent of the parties. This is especially true where the person seeking to invoke unauthorized jurisdiction of the court does not thereby secure any advantage or the adverse party does not suffer any harm. Estoppel by laches explained True, delay alone, though unreasonable, will not sustain the defense of ―estoppel by laches‖ unless it further appears that the party, knowing his rights, has not sought to enforce them until the condition of the party pleading laches has in good faith become so changed that he cannot be restored to his former state, if the rights be then


enforced, due to loss of evidence, change of title, intervention of equities, and other causes. In re: Tijam vs. Sibonghanoy In Sibonghanoy , the defense of lack of jurisdiction of the court that rendered the questioned ruling was held to be barred by estoppel by laches. It was ruled that the lack of jurisdiction having been raised for the first time in a motion to dismiss filed almost fifteen (15) years after the questioned ruling had been rendered, such a plea may no longer be raised for being barred by laches. As defined in said case, laches 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; it is negligence or omission to assert a right within a reasonable time, warranting a presumption that the party entitled to assert has abandoned it or declined to assert it.

It is noteworthy that the party questioning the jurisdiction actively participated in the trial and even raised affirmative reliefs. It was only when the adverse decision was rendered by the Court of Appeals that it finally woke up to raise the question of jurisdiction. This strategy is frowned upon because the party only challenges the jurisdiction for the purpose of nullifying the entire proceedings.

HEIRS OF JANE HONRALES v. JONATHAN HONRALES Requisites of double jeopardy Thus, double jeopardy exists when the following requisites are present: (1) a first jeopardy attached prior to the second; (2) the first jeopardy has been been validly terminated terminated;; and (3) a second second jeopardy jeopardy is for the same offense as in the first. A first jeopardy attaches only (a) after a valid indictment; (b) before a competent court; (c) after arraignment; (d) when a valid plea has been entered; and (e) when

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Marjorie Castillo & Monica Cajucom


the accused has been acquitted or convicted, or the case dismissed or otherwise terminated without his express consent.

court’s jurisdiction, they are deemed to have waived their right to seek judicial relief. relief.

Court where information is filed retains jurisdiction until final determination In this case, the MeTC took cognizance of the Information for reckless imprudence resulting in parricide while the criminal case for parricide was still pending before the RTC. In Dioquino v. Cruz, Jr., we held that once jurisdiction is acquired by the court in which the Information is filed, it is there retained. Therefore, as the offense of reckless imprudence resulting in parricide was included in the charge for intentional parricide pending before the RTC, the MeTC clearly had no jurisdiction jurisdiction over the criminal case filed before it, the RTC having retained jurisdiction over the offense to the exclusion of all other courts. The requisite that the judgment be rendered by a court of competent jurisdiction is therefore absent.

Moreover, this doctrine applies not only to the accused who jumps bail during the appeal, but also to one who does so during the trial. The accused cannot be accorded the right to appeal unless they voluntarily submit to the jurisdiction of the court or are otherwise arrested within 15 days from notice of the judgment against them. While at large, they cannot seek relief from the court, as they are deemed to have waived the appeal. Consequently, the judgment against him has become final and executory.

EQUI-ASIA v. v.DEPARTMENT DEPARTMENT OF FOREIGN AFFAIRS PHILIPPINE RABBIT BUS LINES, INC.v. INC.v.PEOPLE PEOPLE OF THE PHILIPPINES Accused must submit to court’s jurisdiction or custody of the law to avail the right to appeal The second paragraph of Section 8 of Rule 124 of the 2000 Revised Rules of Criminal Procedure provides:

"The Court of Appeals may also, upon motion of the appellee or motuproprio, dismiss the appeal if the appellant escapes from prison or confinement, jumps bail or flees to a foreign country during the pendency of the appeal."

The RTC is a regular court There is no denying that regular courts have jurisdiction over cases involving the validity or constitutionality of a rule or regulation issued by administrative agencies. Such jurisdiction, however, is not limited to the Court of Appeals or to this Court alone for even the regional trial courts can take cognizance of actions assailing a specific rule or set of rules promulgated by administrative bodies. Indeed, the Constitution vests the power of judicial review or the power to declare a law, treaty, international or executive agreement, presidential decree, order, instruction, ordinance, or regulation in the courts, including the regional trial courts.

This rule is based on the rationale that appellants lose their standing in court when they abscond. Unless they surrender or submit to the

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Marjorie Castillo & Monica Cajucom CABRERA v. v. LAPID LAPID

Direct appeal from the issuances of the Ombudsman to the Supreme Court not allowed in criminal cases; declared unconstitutional Clearly, this is an appeal from the questioned issuances of the Ombudsman. However, such direct resort to this Court from a resolution or order of the Ombudsman is not sanctioned by any rule of procedure. Neither can petitioner avail of Sec. 27of R.A. No. 6770, otherwise known as The Ombudsman Act of 1989. The provision allowed direct appeals in administrative disciplinary cases from the Office of the Ombudsman to the Supreme Court. The right to appeal is granted only in respect to orders or decisions of the Ombudsman in administrative cases.The provision does not cover resolutions of the Ombudsman in criminal cases. More importantly, Sec. 27 of R.A. No. 6770 insofar as it allowed a direct appeal to this Court was declared unconstitutional in Fabian v. Hon. Desierto. Desierto. The purported errors in judgment can be corrected by an appeal, although not via a direct appeal to the Supreme Court. Remedy: Petition for certiorari under Rule 65 However, an aggrieved party in criminal actions is not without any recourse. Where grave abuse of discretion amounting to lack or excess of jurisdiction taints the findings of the Ombudsman on the existence of probable cause, the aggrieved party may file a petition for certiorari under Rule 65.

No grave abuse of discretion due to valid exercise of police power A careful reading of the questioned questioned Resolution Resolution reveals that the Ombudsman dismissed petitioner’s criminal complaint because respondents had validly resorted to the police power of the State when they effected the demolition of the illegal fishpond in question


following the declaration thereof as a nuisance per se. Thus, the Ombudsman was of the opinion that no violation of Section 3(e) of the Anti-Graft Anti-Graft and Corrupt Practices Practices Act or of Article 324 of the Revised Revised Penal Code was committed by respondents. In the words of the Ombudsman, ―those who participated in the blasting of the subject fishpond were only impelled by their desire to serve the best interest of the general public; for the good and the highest good.‖ Grave abuse of discretion or error of jurisdiction vs. Error in judgment Grave abuse of discretion should be differentiated from an error in judgment. judgment. An error of judgment is one which which the court may commit in the exercise of its jurisdiction, and which error is reversible only by an appeal. As long as the court acts within its jurisdiction, any alleged errors committed in the exercise of its discretion will amount to nothing more than mere errors of judgment, correctible by an appeal or a petition for review under Rule 45 of the Rules of Court. An error of jurisdiction is one where the act complained of was issued by the court without or in excess of jurisdiction and which error is correctible only by the extraordinary writ of certiorari.

BOKINGCO v. v. COURT COURT OF APPEALS Allegations in the complaint determine jurisdiction It is axiomatic that the nature of the action and which court has original and exclusive jurisdiction over the same is determined by the material allegations of the complaint, the type of relief prayed for by the plaintiff, and the law in effect when the action is filed, irrespective of whether the plaintiffs are entitled to some or all of the claims asserted therein. The caption of the complaint is not determinative of the nature of the action. Nor does the jurisdiction of the court depend

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Marjorie Castillo & Monica Cajucom upon the answer of the defendant or agreement of the parties, or to the waiver or acquiescence of the parties. RTC has jurisdiction over cases where money claim is only purely incidental or a consequence of the principal relief which is incapable of pecuniary estimation In this connection, it is well to note that the Court had the occasion to explain that "in determining whether an action is one the subject matter of which is not capable of pecuniary estimation, the nature of the principal action, or remedy sought must first be ascertained. If it is primarily for the recovery of a sum of money, the claim is considered capable of pecuniary estimation, and jurisdiction over the action will 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, the action is one where the subject of litigation may not be estimated in terms of money, which is cognizable exclusively by Regional Trial Courts."

GONZALES v. v. ABAYA ABAYA General rule: crimes or offenses committed by the members of the AFP and other persons subject to military law fall under the jurisdiction of the proper civil court; Exception; Exception to the exception

Section 1 of R.A. No. 7055, quoted above, is clear and unambiguous. First, it lays down the general rule that members of the AFP and other persons subject to military law, including members of the Citizens Armed Forces Geographical Geographical Units, who commit crimes or offenses offenses penalized under the Revised Penal Code (like coup d’etat ), ), other special penal laws, or local ordinances shall be tried by the proper civil court. Next, it provides the exception to the general rule, i.e.,


where the civil court, before arraignment, has determined the offense to be service-connected, then the offending soldier shall be tried by a court martial. Lastly, the law states an exception to the exception, i.e., where the President of the Philippines, in the interest of justice, directs before arraignment that any such crimes or offenses be tried by the proper civil cour. Service-connected crimes or offenses explained The second paragraph of the same provision further identifies the "service-connected crimes or offenses" as " limited to those defined in Articles 54 to 70, Articles 72 to 92, and Articles 95 to 97" of the Articles of War. Violations Violations of these specified specified Articles are triable by court martial. This delineates the jurisdiction between the civil courts and the court martial over crimes or offenses committed by military personnel.

Such delineation of jurisdiction by R.A. No. 7055 is necessary to preserve the peculiar nature of military justice system over military personnel charged with service-connected offenses. The military justice system system is disciplinary in nature, nature, aimed at at achieving achieving the highest highest form of discipline in order to ensure the highest degree of military efficiency.Here, petitioners are charged for violation of Article 96 (conduct unbecoming an officer and a gentleman) of the Articles of War before the court martial. It bears stressing that the charge against the petitioners concerns the alleged violation of their solemn oath as officers to defend the Constitution and the duly-constituted authorities.Such violation allegedly caused dishonor and disrespect to the military profession. In short, the charge has a bearing on their professional conduct or behavior as military mili tary off icers. Equally indicative of the "service-connected" nature of the offense is the penalty prescribed for the same –dismissal from the service – imposable only by the military court.Such penalty is purely

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Marjorie Castillo & Monica Cajucom disciplinary in character, evidently intended to cleanse the military profession of misfits and to preserve the stringent standard of military discipline. Only the Constitution or the law can bestow jurisdiction— jurisdiction—not the courts The RTC, in making such declaration, practically amended the law which expressly vests in the court martial the jurisdiction over "service-connected crimes or offenses." What the law has conferred the court should not take away. It is only the Constitution or the law that bestows jurisdiction on the court, tribunal, body or officer over the subject matter or nature of an action which can do so.And it is only through a constitutional amendment or legislative enactment that such act can be done. The first and fundamental duty of the courts is merely to apply the law "as they find it, not as they like it to be."


Principal action or remedy determines whether the subject matter is capable 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. I f itit i s p r i m a r i l y f o r t h e r e c o v e r y o f a s u m o f m o n e y , t h e c l a im im i s c o n s i d e r e d c a p a b l e o f p e c u n i a r y e s t i m a t i o n , and whether jurisdiction is in the municipal courts o r in the courts of first instance [now Regional Trial Courts] would d e p e n d o n t h e a m o u n t o f t h e c l a i m . 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 like suits to have the defendant perform his part of the contract (specific performance) and in actions for support, or for annulment of a judgment or to foreclose a mortgage, 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 courts of first instance [now Regional Trial Courts].

INIEGO v. v. PURAGANAN PURAGANAN Subject matter is the measure whether or not it is capable of pecuniary estimation— estimation—not the cause of action; Subject matter vs. Cause of action It is crystal clear from B.P. Blg. 129, as amended by Republic Act No. 7691, that what must be determined to be capable or incapable of pecuniary estimation is not the cause of action, but the subject of the action. A cause of action action is ―the delict delict or wr ongful wr ongful act or matter of omission committed by the defendant in violation of the primary rights of the plaintiff.‖ On the other hand, the ―subject matter of the action‖ is ―the physical facts, the thing real or personal, the money, lands, chattels, and the like, in relation to which the suit is prosecuted, and not the delict or wrong committed by the defendant.‖

Action for damages based on a quasi-delict is capable of pecuniary estimation Actions for damages damages based on quasi-delicts quasi-delicts are primarily and effectively actions for the recovery of a sum of money for the damages suffered because of the defendant’s alleged tortious acts. The damages claimed in such actions represent the monetary equivalent of the injury caused to the plaintiff by the defendant, which are thus sought to be recovered by the plaintiff. This money claim is the principal relief sought, and is not merely incidental thereto or a consequence thereof. Fault or negligence is not capable of pecuniary estimation when not accompanied by a resulting damage Fault or negligence, which the Court of Appeals claims is not capable of pecuniary estimation, is not actionable by itself. For such fault or

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Marjorie Castillo & Monica Cajucom negligence to be actionable, there must be a resulting damage to a third person. The relief available to the offended party in such cases is for the reparation, restitution, or payment of such damage, without which any alleged offended party has no cause of action or relief. The fault or negligence of the defendant, therefore, is inextricably intertwined with the claim for damages, and there can be no action based on quasi-delict without a claim for damages.

BERNAS v. v. SOVEREIGN SOVEREIGN VENTURES Service of summons required in an application for a writ of preliminary injunction or TRO; Exception Section 4 (c) , Rule 58 of the 1997 Rulesof Civil Procedure, Proc edure, as amended. The provision now reads as follows:

(c) When an application for a writ of preliminary injunction or a temporary restraining order is included in a complaint or any initiatory pleading, the case, if filed in a multiple-sala court, shall be raffled only after notice to and in the presence of the adverse party or the person to be enjoined. In any event, such notice shall be preceded, or contemporaneously accompanied, by service of summons, together with a copy of the complaint or initiatory pleading and the applicant’s affidavit and bond, upon the adverse party in the Philippines. However, where the summons could not be served personally or by substituted service despite diligent efforts, or the adverse party is a resident of the Philippines temporarily absent therefrom or is non-


resident thereof, the requirement of prior or contemporaneous service of summons shall not apply.

Jurisdiction is acquired through service of summons or voluntary appearance Moreover, as held by the trial court, petitioner voluntarily submitted himself to the jurisdiction of the said court. Records show that he filed a Motion for a Bill of Particulars, Motion to Cite Respondent and Counsel in Contempt of Court, praying for ―other ―other reliefs, just and equitable.‖ He filed an Omnibus Motion assailing the trial court’s order restraining the annotation of lis pendens on the titles of the property in litigation. He participated in the hearing of this motion. And lastly, he filed a motion to dismiss.

A court generally acquires jurisdiction over a person through either a valid service service of summons or the person’s voluntary appearance in court.

UNION BANK v. SECURITIES AND EXCHANGE COMMISSION Intra-corporate cases transferred from SEC to RTC; Pending cases not included Republic Act No. 8799, otherwise known as the Securities Regulation Code, was approved by then Pres. Estrada on July 19, 2000. The law transferred the SEC's original and exclusive jurisdiction over intracorporate cases to the courts of general jurisdiction or the appropriate Regional Trial Court (RTC) except for "pending cases involving intracorporate disputes submitted for final resolution which should be resolved within one (1) year from the enactment of [the] Code."

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Marjorie Castillo & Monica Cajucom Jurisdiction includes the execution of judgment; Exception The grant to a tribunal or agency of adjudicatory power, or the authority to hear and adjudge cases, should normally and logically be deemed to include the grant of authority to enforce or execute the judgments judgments it renders, unless the law otherwise provides. This is so because the authority to decide cases is inutile unless accompanied by the authority to see to it that what has been decided is carried out. A case at the execution stage is still considered a pending case Petitioner's contention that the SEC does not have jurisdiction to execute because once decided, the case ceases to be a "pending" case and becomes a "decided" case deserves scant attention. In the first place, we have repeatedly held that a case in which an execution has been issued is considered as still "pending" so that all proceedings on the execution are proceedings in the suit.

A long standing standing doctrine doctrine is that the tribunal tribunal which rendered the decision or award has a general supervisory control over the process of its execution, and this includes the power to determine every question of fact and law which may be involved in the execution.

GOLANGCO v. v. FUNG FUNG The CA does not have jurisdiction over criminal or nonadministrative cases decided by the Office of the Ombudsman The Court of Appeals has jurisdiction over orders, directives and decisions of the Office of the Ombudsman in administrative disciplinary cases only. It cannot, therefore, review the orders, directives or decisions of the Office of the Ombudsman in criminal or non-administrative cases.


MISON v. v. NATIVIDAD NATIVIDAD The Collector of Customs has exclusive jurisdiction over seizure and forfeiture proceedings The respondent Judge, therefore, acted arbitrarily and despotically in issuing the temporary restraining order, granting the writ of preliminary injunction and denying the motion to dismiss, thereby removing the res from the control of the Collector of Customs and depriving him of his exclusive original jurisdiction over the controversy. Respondent Judge exercised a power he never had and encroached upon the exclusive original jurisdiction of the Collector of Customs. By express provision of law, amply supported by well-settled jurisprudence, the Collector of Customs has exclusive jurisdiction over seizure and forfeiture proceedings and regular courts cannot interfere with his exercise thereof or stifle or put it to naught. Neither payment of taxes and licenses (allegations of ownership) nor the illegality of the warrant of seizure and detention divest the Collector of Customs of jurisdiction jurisdiction or justify the trial court’s interference Private respondent alleges ownership over several vehicles which are legally registered in his name, having paid all the taxes and corresponding licenses incident thereto, neither divests the Collector of Customs of such jurisdiction nor confers upon the said trial court regular jurisdiction over the case. Even the illegality of the warrant of seizure and detention cannot justify the trial court’s interference with the Collector’s Coll ector’s jurisdiction. In the first place, there is a distinction between the existence of the Collector’s power to issue it and the regularity of the proceeding taken under such power. In the second place, even if there be such an irregularity in the latter, the Regional Trial Court does not have the competence to review, modify or reverse whatever conclusions may result therefrom.

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COMMISSIONER OF CUSTOMS v. v.COURT COURT OF APPEALS, ET. AL

Trial courts cannot interfere with the Collector of Customs even through proceedings under Rule 65 This Court again reminds all concerned that the rule is clear: the Collector of Customs has exclusive jurisdiction over seizure and forfeiture proceedings and trial courts are precluded from assuming cognizance over such matters even through petitions for certiorari, prohibition or mandamus. Jurisdiction over the re s must be first acquired The Bureau of Customs had acquired jurisdiction over the res ahead and to the exclusion of the RTC of Manila. The forfeiture proceedings conducted by the Bureau of Customs are in the nature of proceedings in rem and jurisdiction was obtained from the moment the vessel entered the SFLU port.

DANILO G. PUNONGBAYAN v. v.PERFECTO PERFECTO G. PUNONGBAYAN, PUNONGBA YAN, JR., MARILOU P. VISITACION, and SOTERO A. PUNONGBAYAN The RTC can re-organize management committees of corporations Republic Act No. 8799, which became effective on August 8, 2000, transferred the jurisdiction of the SEC over cases involving intracorporate disputes to the Regional Trial Courts. Thus, the RTC assumed powers provided under Sections 5 and 6 of Presidential Decree No. 902-A quoted earlier. As such, it has the discretion to


grant or deny an application for the creation of a management committee. This discretion, however, must be exercised with great caution and circumspection. Having the power to create a management committee, it follows that the RTC can order the reorganization of the existing management committee. Here, knowing that the deadlock among the members of the committee (appointed by the SEC) may lead to the paralyzation of the school’s business operations, the RTC removed the said members and appointed new members.

SPOUSES EDMUNDO T. OSEA AND LIGAYA R. OSEA v.ANTONIO v. ANTONIO G. AMBROSIO AND RODOLFO C. PEREZ Jurisdiction of administrative agencies determined by the statute that created or empowering it Presidential Decree (P.D.) No. 1344 clarifies and spells out the quasi judicial dimensions dimensions of the grant of jurisdiction to the HLURB in the following specific terms:

SEC. 1. In the exercise of its functions to regulate the real estate trade and business and in addition to its powers provided for in Presidential Decree No. 957, the National Housing Authority shall have exclusive jurisdiction to hear and decide cases of the following nature: A. Unsound real estate business practices; B. Claims involving refund and any other claims filed by subdivision lot or condominium unit buyer against the project owner, developer, dealer, broker or salesman; and

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C. Cases involving specific performance of contractual and statutory obligations filed by buyers of subdivision lots or condominium units against the owner, developer, dealer, broker or salesman. (Emphasis supplied)

The HLURB has quasi-judicial authority because of its technical expertise on the subject matter The business of developing subdivisions and corporations being imbued with public interest and welfare, any question arising from the exercise of that prerogative should be brought to the HLURB which has the technical know-how on the m atter. In the exerci se of its powers, the HLURB must commonly interpret and apply contracts and determine the rights of private parties under such contracts. This ancillary power is no longer a uniquely judicial function, exercisable only by the regular courts. Doctrine of Primary Administrative Jurisdiction Moreover, under the doctrine of primary administrative jurisdiction, courts cannot or will not determine a controversy where the issues for resolution demand the exercise of sound administrative discretion requiring the special knowledge, experience, and services of the administrative tribunal to determine technical and intricate matters of fact.


ALCARAZ v. v. GONZALEZ GONZALEZ The determination of probable cause is exclusive to the Department of Justice— Justice—the CA cannot interfere via appeal It bears stressing that in the determination of probable cause during the preliminary investigation, the executive branch of government has full discretionary authority. Thus, the decision whether or not to dismiss the criminal complaint against the private respondent is necessarily dependent on the sound discretion of the Investigating Prosecutor and ultimately, that of the Secretary of Justice. Courts are not empowered to substitute their own judgment for that of the executive branch . The resolution of the Investigating Prosecutor is subject to appeal to the Justice Secretary who, under the Revised Administrative Code, exercises the power of control and supervision over said Investigating Prosecutor; and who may affirm, nullify, reverse, or modify the ruling of such prosecutor. The CA can interfere only in a petition for certiorari under Rule 65 Thus, while the CA may review the resolution of the Justice Secretary, it may do so only in a petition for certiorari under Rule 65 of the Rules of Court, solely on the ground that the Secretary of Justice committed grave abuse of his discretion amounting to excess or lack of jurisdiction.

RIDGEWOOD ESTATE v. v. BELAOS BELAOS Under the circumstances attendant to the case, the HLURB has the expertise to determine the basic technical issue of whether the alleged deviations from the building plans and the technical specifications affect the soundness and structural strength of the house.

The nature of the claim determines the jurisdiction of the case; A claim for damages falls under the jurisdiction of the regular courts The Court held in Roxas v. Court of Appeals, Appeals, that the mere relationship between the parties, i.e., that of being subdivision owner/developer and subdivision lot buyer, does not automatically

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Marjorie Castillo & Monica Cajucom vest jurisdiction in the HLURB. For an action to fall within the exclusive jurisdiction of the HLURB, the decisive element is the nature of the action as enumerated in Section 1 of P.D. No. 1344. The HLURB has jurisdiction over complaints aimed at compelling the subdivision developer to comply with its contractual and statutory obligations. The complaint filed by respondent against petitioner was one for damages. It prayed for the payment of moral, actual and exemplary damages by reason of petit ioner’s malicious encashment of the checks even after the rescission of the contract to sell between them. Respondent claimed that because of petitioner’s malicious and fraudulent acts, he suffered humiliation and embarrassment in several banks, causing him to lose his credibility and good standing among his colleagues. Such action falls within the jurisdiction of regular courts, not the HLURB.

SANTE v. v. CLARAVALL CLARAVALL Adjustment of jurisdictional amounts in gross value, claim, or demand After five (5) years from the effectivity effectivity of this Act, the jurisdictional jurisdictional amounts mentioned in Sec. 19(3), (4), and (8); and Sec. 33(1) of Batas PambansaBlg. 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 jurisdictional amounts shall be adjusted after five (5) years from the effectivity of this Act to Four hundred thousand pesos (P 400,000.00).


When damages is the main cause of the action or one of the causes of action, the total amount shall be the basis of jurisdiction, which i ncludes moral and exemplary damages, etc. It is settled that jurisdiction is conferred by law based on the facts alleged in the complaint since the latter comprises a concise statement of the ultimate facts constituting the plaintiff’s causes of action. It is clear, based on the allegations of the complaint, that respondent’s main action is for damages. Hence, the other forms of damages being claimed by respondent, e.g., exemplary damages, attorney’s fees and litigation expenses, are not merely incidental to or consequences of the main action but constitute the primary relief prayed for in the complaint.

VICTORINO QUINAGORANv. QUINAGORANv.COURT COURT OF APPEALS and THE HEIRS OF JUAN DE LA CRUZ Assessed value of real property determines jurisdiction As things now stand, a distinction distinction must be made between between those properties the assessed value of which is below P20,000.00, if outside Metro Manila; and P50,000.00, if within.

In Atuel v. Valdez the the Court likewise expressly stated that: Jurisdiction over an accion publiciana is vested in a court of general jurisdiction. Specifically, the regional trial court exercises exclusive original jurisdiction ―in all civil actions which involve x x x possession of real property.‖ property.‖ However, if the assessed value of the real property involved does not exceed P50,000.00 in Metro Manila, and P20,000.00 outside of Metro Manila, the municipal trial court exercises jurisdiction over actions to recover possession of real property.

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Complaint must allege the assessed value of the real property In no uncertain terms, the Court has already held that a complaint must allege the assessed value of the real property subject of the complaint or the interest thereon to determine which court has jurisdiction jurisdiction over the action. This is because the nature of the action and which court has original and exclusive jurisdiction over the same is determined by the material allegations of the complaint, the type of relief prayed for by the plaintiff and the law in effect when the action is filed, irrespective of whether the plaintiffs are entitled to some or all of the claims asserted therein. Jurisdiction does not depend on the answer of the defendant or on agreement, waiver, or acquiescence of the parties Jurisdiction of the court does not depend upon the answer of the defendant or even upon agreement, waiver or acquiescence of the parties. Indeed, 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 for, otherwise, the question of jurisdiction would depend almost entirely on the defendant.

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Jurisdiction Case Doctrines (Compilation)

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