JURISDICTION

1. Eristingcol vs. Court of Appeals, 582 SCRA 139 , March 20, 2009
A. Well-settled in jurisprudence is the rule that in determining which body has
jurisdiction over a case, we should consider not only the status or relationship
of the parties, but also the nature of the question that is the subject of their
controversy.[6] To determine the nature of an action and which court has
jurisdiction, courts must look at the averments of the complaint or petition
and the essence of the relief prayed for.
B. Eristingcols complaint, designated as one for declaration of nullity, falls
within the regular courts jurisdiction. However, we have, on more than one
occasion, held that the caption of the complaint is not determinative of the
nature of the action. A scrutiny of the allegations contained in Eristingcols
complaint reveals that the nature of the question subject of this controversy
only superficially delves into the validity of UVAIs Construction Rules. The
complaint actually goes into the proper interpretation and application of
UVAIs by-laws, specifically its construction rules. Essentially, the conflict
between the parties arose as Eristingcol, admittedly a member of UVAI, now
wishes to be exempt from the application of the canopy requirement set forth
in UVAIs Construction Rules. Significantly, Eristingcol does not assail the
height restriction of UVAIs Construction Rules, as she has readily complied
therewith.
2. Duero vs. Court of Appeals, 373 SCRA 11 , January 04, 2002
A. Actions; Jurisdiction; Estoppel; While participation in all stages of a case
before the trial court, including invocation of its authority in asking for
affirmative relief, effectively bars a party by estoppel from challenging the
courts jurisdiction, the Court notes that estoppel has become an equitable
defense that is both substantive and remedial and its successful invocation
can bar a right and not merely its equitable enforcement; For estoppel to
apply, the action giving rise thereto must be unequivocal and intentional
because, if misapplied, estoppel may become a tool of injustice.Was private respondent estopped from questioning the jurisdiction of the
RTC? In this case, we are in agreement with the Court of Appeals that he was
not. While participation in all stages of a case before the trial court, including
invocation of its authority in asking for affirmative relief, effectively bars a
party by estoppel from challenging the courts jurisdiction, we note that
estoppel has become an equitable defense that is both substantive and
remedial and its successful invocation can bar a right and not merely its
equitable enforcement. Hence, estoppel ought to be applied with caution. For
estoppel to apply, the action giving rise thereto must be unequivocal and
intentional because, if misapplied, estoppel may become a tool of injustice.
B. Actions; Jurisdiction; Estoppel; The fundamental rule is that, the lack of
jurisdiction of the court over an action cannot be waived by the parties, or
even cured by their silence, acquiescence or even by their express consent;
Even if a party actively participated in the proceedings before the trial court,

the doctrine of estoppel cannot still be properly invoked against him because
the question of lack of jurisdiction may be raised at anytime and at any stage
of the action.Under these circumstances, we could not fault the Court of Appeals in
overruling the RTC and in holding that private respondent was not estopped
from questioning the jurisdiction of the regional trial court. The fundamental
rule is that, the lack of jurisdiction of the court over an action cannot be
waived by the parties, or even cured by their silence, acquiescence or even
by their express consent. Further, a party may assail the jurisdiction of the
court over the action at any stage of the proceedings and even on appeal.
The appellate court did not err in saying that the RTC should have declared
itself barren of jurisdiction over the action. Even if private respondent actively
participated in the proceedings before said court, the doctrine of estoppel
cannot still be properly invoked against him because the question of lack of
jurisdiction may be raised at anytime and at any stage of the action.
Precedents tell us that as a general rule, the jurisdiction of a court is not a
question of acquiescence as a matter of fact, but an issue of conferment as a
matter of law. Also, neither waiver nor estoppel shall apply to confer
jurisdiction upon a court, barring highly meritorious and exceptional
circumstances.
C. Actions; Jurisdiction; Appeals; Certiorari; Since a decision of a court without
jurisdiction is null and void, it could logically never become final and
executory, hence appeal therefrom by writ of error would be out of the
questiona petition for certiorari would be in order.Since a decision of a court without jurisdiction is null and void, it could
logically never become final and executory, hence appeal therefrom by writ
of error would be out of the question. Resort by private respondent to a
petition for certiorari before the Court of Appeals was in order.

3. Gonzaga vs. Court of Appeals, 394 SCRA 472 , December 27, 2002
A. Remedial Law; Estoppel; While an order or decision rendered without
jurisdiction is a total nullity and may be assailed at any stage, active
participation in the proceedings in the court which rendered the order or
decision will bar such party from attacking its jurisdiction.Petitioners claim that the recent decisions of this Court have already
abandoned the doctrine laid down in Tijam vs. Sibonghanoy. We do not
agree. In countless decisions, this Court has consistently held that, while an
order or decision rendered without jurisdiction is a total nullity and may be
assailed at any stage, active participation in the proceedings in the court
which rendered the order or decision will bar such party from attacking its
jurisdiction.

B. Remedial Law; Estoppel; Court frowns upon the undesirable practice of a

party submitting his case for decision and then accepting the judgment but
only if favorable, and attacking it for lack of jurisdiction if not.Petitioners should bear the consequence of their act. They cannot be allowed
to profit from their omission to the damage and prejudice of the private
respondent. This Court frowns upon the undesirable practice of a party
submitting his case for decision and then accepting the judgment but only if
favorable, and attacking it for lack of jurisdiction if not.
4. Escobal vs. Garchitorena, 422 SCRA 45 , February 05, 2004
A. Criminal Law; Courts; Jurisdiction; Criminal Procedure; Pleadings and Practice;
The jurisdiction of the court over criminal cases is determined by the
allegations in the Information or the Complaint and the statute in effect at the
time of the commencement of the action, unless such statute provides for a
retroactive application thereof.The respondent Presiding Justice acted in accordance with law and the rulings
of this Court when he ordered the remand of the case to the RTC, the court of
origin. The jurisdiction of the court over criminal cases is determined by the
allegations in the Information or the Complaint and the statute in effect at the
time of the commencement of the action, unless such statute provides for a
retroactive application thereof. The jurisdictional requirements must be
alleged in the Information. Such jurisdiction of the court acquired at the
inception of the case continues until the case is terminated.
B. Criminal Law; Courts; Jurisdiction; Sandiganbayan; Public Officers; For the
Sandiganbayan to have exclusive jurisdiction under Section 4(a) of P.D. No.
1606, as amended by P.D. No. 1861 over crimes committed by public officers
in relation to their office, it is essential that the facts showing the intimate
relation between the office and the offender and the discharge of official
duties must be alleged in the Informationit is not enough to merely allege
in the Information that the crime charged was committed by the offender in
relation to his office because that would be a conclusion of law.However, for the Sandiganbayan to have exclusive jurisdiction under the said
law over crimes committed by public officers in relation to their office, it is
essential that the facts showing the intimate relation between the office of
the offender and the discharge of official duties must be alleged in the
Information. It is not enough to merely allege in the Information that the
crime charged was committed by the offender in relation to his office because
that would be a conclusion of law. The amended Information filed with the
RTC against the petitioner does not contain any allegation showing the
intimate relation between his office and the discharge of his duties. Hence,
the RTC had jurisdiction over the offense charged when on November 24,
1995, it ordered the re-amendment of the Information to include therein an
allegation that the petitioner committed the crime in relation to office. The
trial court erred when it ordered the elevation of the records to the
Sandiganbayan. It bears stressing that R.A. No. 7975 amending P.D. No. 1606
was already in effect.

C. Criminal Law; Courts; Jurisdiction; Sandiganbayan; Public Officers; Under R.A.

7975, even if the offender committed the crime charged in relation to his
office but occupies a position corresponding to a salary grade below 27, the
proper Regional Trial Court or Municipal Trial Court, as the case may be, shall
have exclusive jurisdiction over the case.Under the law, even if the offender committed the crime charged in relation
to his office but occupies a position corresponding to a salary grade below
27, the proper Regional Trial Court or Municipal Trial Court, as the case may
be, shall have exclusive jurisdiction over the case. In this case, the petitioner
was a Police Senior Inspector, with salary grade 23. He was charged with
homicide punishable by reclusion temporal. Hence, the RTC had exclusive
jurisdiction over the crime charged conformably to Sections 20 and 32 of
Batas Pambansa Blg. 129, as amended by Section 2 of R.A. No. 7691.
D. Criminal Law; Courts; Jurisdiction; Sandiganbayan; Statutes; R.A. No. 7975 is
a substantive procedural law which may be applied retroactively.The petitioners contention that R.A. No. 7975 should not be applied
retroactively has no legal basis. It bears stressing that R.A. No. 7975 is a
substantive procedural law which may be applied retroactively.
5. Liga ng mga Barangay National vs. Atienza, Jr., 420 SCRA 562 , January
21, 2004
A. Actions; Pleadings and Practice; Certiorari; Concurrent Jurisdiction; A
becoming regard of that judicial hierarchy most certainly indicates that
petitions for the issu-ance of extraordinary writs against first level (inferior)
courts should be filed with the Regional Trial Court, and those against the
latter, with the Court of Appeals.This concurrence of jurisdiction is not, however, to be taken as according to
parties seeking any of the writs an absolute, unrestrained freedom of choice
of the court to which application therefore will be directed. There is after all a
hierarchy of courts. That hierarchy is determinative of the venue of appeals,
and also serves as a general determinant of the appropriate forum for
petitions for the extraordinary writs. A becoming regard of that judicial
hierarchy most certainly indicates that petitions for the issuance of
extraordinary writs against first level (inferior) courts should be filed with
the Regional Trial Court, and those against the latter, with the Court of
Appeals. A direct invocation of the Supreme Courts original jurisdiction to
issue these writs should be allowed only when there are special and
important reasons therefor, clearly and specifically set out in the petition.
This is [an] established policy. It is a policy necessary to prevent inordinate
demands upon the Courts time and attention which are better devoted to
those matters within its exclusive jurisdiction, and to prevent further
overcrowding of the Courts docket.
6. Serana vs. Sandiganbayan, 542 SCRA 224 , January 22, 2008

A. The rule is well-established in this jurisdiction that statutes should receive a

sensible construction so as to avoid an unjust or an absurd conclusion.
Interpretatio talis in ambiguis semper fienda est, ut evitetur inconveniens et
absurdum. Where there is ambiguity, such interpretation as will avoid
inconvenience and absurdity is to be adopted. Kung saan mayroong
kalabuan, ang pagpapaliwanag ay hindi dapat maging mahirap at katawatawa.
Every section, provision or clause of the statute must be expounded by
reference to each other in order to arrive at the effect contemplated by the
legislature. The intention of the legislator must be ascertained from the
whole text of the law and every part of the act is to be taken into view. In
other words, petitioners interpretation lies in direct opposition to the rule
that a statute must be interpreted as a whole under the principle that the
best interpreter of a statute is the statute itself. Optima statuti interpretatrix
est ipsum statutum. Ang isang batas ay marapat na bigyan ng kahulugan sa
kanyang kabuuan sa ilalim ng prinsipyo na ang pinakamainam na
interpretasyon ay ang mismong batas.
B. The Sandiganbayan has jurisdiction over other felonies committed by public
officials in relation to their office. We see no plausible or sensible reason to
exclude estafa as one of the offenses included in Section 4(B) of P.D. No.
1606. Plainly, estafa is one of those other felonies. The jurisdiction is simply
subject to the twin requirements that (a) the offense is committed by public
officials and employees mentioned in Section 4(A) of P.D. No. 1606, as
amended, and that (b) the offense is committed in relation to their office.
C. Petitioner claims that she is not a public officer with Salary Grade 27; she is,
in fact, a regular tuition fee-paying student. This is likewise bereft of merit. It
is not only the salary grade that determines the jurisdiction of the
Sandiganbayan. The Sandiganbayan also has jurisdiction over other officers
enumerated in P.D. No. 1606. In Geduspan v. People, We held that while the
first part of Section 4(A) covers only officials with Salary Grade 27 and
higher, its second part specifically includes other executive officials whose
positions may not be of Salary Grade 27 and higher but who are by express
provision of law placed under the jurisdiction of the said court. Petitioner falls
under the jurisdiction of the Sandiganbayan as she is placed there by
express provision of law.
D. It is axiomatic that jurisdiction is determined by the averments in the
information. More than that, jurisdiction is not affected by the pleas or the
theories set up by defendant or respondent in an answer, a motion to
dismiss, or a motion to quash. Otherwise, jurisdiction would become
dependent almost entirely upon the whims of defendant or respondent.
7. Ambil, Jr. vs. Sandiganbayan, 653 SCRA 576 , July 06, 2011
A. Same; Same; Sandiganbayan; Jurisdiction; Conspiracy; It is only when none
of the accused are occupying positions corresponding to salary grade 27 or

higher that exclusive jurisdiction be vested in the lower courts and not in the
Sandiganbayan.
The jurisdiction of the Sandiganbayan over petitioner Ambil, Jr. is beyond
question. The same is true as regards petitioner Apelado, Sr. As to him, a
Certification from the Provincial Government Department Head of the HRMO
shows that his position as Provincial Warden is classified as Salary Grade 22.
Nonetheless, it is only when none of the accused are occupying positions
corresponding to salary grade 27 or higher shall exclusive jurisdiction be
vested in the lower courts. Here, petitioner Apelado, Sr. was charged as a coprincipal with Governor Ambil, Jr., over whose position the Sandiganbayan
has jurisdiction. Accordingly, he was correctly tried jointly with said public
officer in the proper court which had exclusive original jurisdiction over them
the Sandiganbayan.
8. Platinum Tours and Travel, Incorporated vs. Panlilio, 411 SCRA 142 ,
September 16, 2003
A. Remedial Law; Courts; Jurisdiction; Jurisdiction is the power and authority of
the court to hear, try and decide a case.Jurisdiction is the power and authority of the court to hear, try and decide a
case. In general, jurisdiction may either be over the nature of the action,
over the subject matter, over the person of the defendants or over the
issues framed in the pleadings.
B. Remedial Law; Courts; Jurisdiction; Jurisdiction over the nature of the action
and subject matter is conferred by law.Jurisdiction over the nature of the action and subject matter is conferred by
law. It is determined by the allegations of the complaint, irrespective of
whether or not the plaintiff is entitled to recover upon all or some of the
claims asserted therein. Jurisdiction over the person of the plaintiff is
acquired from the time he files his complaint; while jurisdiction over the
person of the defendant is acquired by his voluntary appearance in court
and his submission to its authority, or by the coercive power of legal
processes exerted over his person.
C. Remedial Law; Courts; Jurisdiction; Jurisdiction does not depend upon the
regularity of the exercise by the court of that power or on the correctness of
its decisions.Since jurisdiction is the power to hear and determine a particular case, it
does not depend upon the regularity of the exercise by the court of that
power or on the correctness of its decisions.
D. Remedial Law; Courts; Jurisdiction; Jurisdiction Distinguished from the
Exercise of Jurisdiction.-

Jurisdiction should be distinguished from the exercise of jurisdiction.

Jurisdiction refers to the authority to decide a case, not the orders or the
decision rendered therein. Accordingly, where a court has jurisdiction over
the person and the subject matter, as in the instant case, the decision on all
questions arising from the case is but an exercise of such jurisdiction. Any
error that the court may commit in the exercise of its jurisdiction is merely
an error of judgment which does not affect its authority to decide the case,
much less divest the court of the jurisdiction over the case.
9. Manila Bankers Life Insurance Corporation vs. Ng Kok Wei, 418 SCRA
454 , December 12, 2003
A. Actions; Jurisdiction; Condominiums; Housing and Land Use Regulatory
Board (HLURB); Complaints for specific performance with damages by a lot
or condominium unit buyer against the owner or developer falls under the
exclusive jurisdiction of the HLURB.Pursuant to the above provisions, it is the HLURB which has jurisdiction over
the instant case. We have consistently held that complaints for specific
performance with damages by a lot or condominium unit buyer against the
owner or developer falls under the exclusive jurisdiction of the HLURB.
B. Actions; Jurisdiction; Condominiums; Housing and Land Use Regulatory
Board (HLURB); Estoppel; Where a party failed to raise the question of
jurisdiction before the trial court and the appellate court, it, in effect,
confirmed and ratified the trial courts jurisdiction over the case and is now
in estoppel and can no longer question the trial courts jurisdiction.While it may be true that the trial court is without jurisdiction over the case,
petitioners active participation in the proceedings estopped it from
assailing such lack of it. We have held that it is an undesirable practice of a
party participating in the proceedings and submitting its case for decision
and then accepting the judgment, only if favorable, and attacking it for lack
of jurisdiction, when adverse. Here, petitioner failed to raise the question of
jurisdiction before the trial court and the Appellate Court. In effect,
petitioner confirmed and ratified the trial courts jurisdiction over this case.
Certainly, it is now in estoppel and can no longer question the trial courts
jurisdiction.
C. Actions; Jurisdiction; The jurisdiction of the Supreme Court in a petition for
review on certiorari under Rule 45 of the 1997 Rules of Civil Procedure, as
amended, is limited to reviewing only errors of law, not of fact, unless the
factual findings being assailed are not supported by evidence on record or
the impugned judgment is based on a misapprehension of facts.On petitioners claim that it did not incur delay, suffice it to say that this is a
factual issue. Time and again, we have ruled that the factual findings of
the trial court are given weight when supported by substantial evidence and
carries more weight when affirmed by the Court of Appeals. Whether or not
petitioner incurred delay and thus, liable to pay damages as a result

thereof, are indeed factual questions. The jurisdiction of this Court in a

petition for review on certiorari under Rule 45 of the 1997 Rules of Civil
Procedure, as amended, is limited to reviewing only errors of law, not of
fact, unless the factual findings being assailed are not supported by
evidence on record or the impugned judgment is based on a
misapprehension of facts. These exceptions are not present here.
10. Government Service Insurance System vs. Santiago, 414 SCRA 563 ,
October 28, 2003
A. Remedial Law; Certiorari; Jurisdiction of the Supreme Court in a petition for
review on certiorari under Rule 45 of the Rules of Court is limited to
reviewing only errors of law.At the outset, it bears emphasis that the jurisdiction of this Court in a
petition for review on certiorari under Rule 45 of the Rules of Court, as
amended, is limited to reviewing only errors of law. This Court is not a trier of
facts. Case law has it that the findings of the trial court especially when
affirmed by the CA are binding and conclusive upon this Court. Although
there are exceptions to the said rule, we find no reason to deviate therefrom.
By assailing the findings of facts of the trial court as affirmed by the CA, that
it acted in bad faith, the petitioner thereby raised questions of facts in its
petition.