CRISANTA ALCARAZ MIGUEL vs JERRY D.

MONTANEZ,
G.R. No. 191336
In the case at bar, the Revised Katarungang
Pambarangay Law provides for a two-tiered
mode of enforcement of an amicable
settlement, to wit: (a) by execution by the
Punong Barangay which is quasi-judicial and
summary in nature on mere motion of the
party entitled thereto; and (b) an action in
regular form, which remedy is judicial.
However, the mode of enforcement does not
rule out the right of rescission under Art.
2041 of the Civil Code. The availability of the
right of rescission is apparent from the
wording of Sec. 417 itself which provides that
the amicable settlement "may" be enforced
by execution by the lupon within six (6)
months from its date or by action in the
appropriate city or municipal court, if beyond
that period. The use of the word "may"
clearly makes the procedure provided in the
Revised Katarungang Pambarangay Law
directory or merely optional in nature.
G.R. No. 198718
2013

November 27,

SPOUSES TEODORO and ROSARIO SARAZA

and FERNANDO SARAZA, Petitioners, vs.
WILLIAM FRANCISCO, Respondent.
When the cases venue was raised as an
issue, the Court sided with therein petitioner
who argued that "the fact that she
ultimately sought the conveyance of real
property not located in the territorial
jurisdiction of the RTC of Pasig is x x x an
anticipated consequence and beyond the
cause for which the action [for specific
performance with damages] was instituted."
The Court reiterated the rule that a case for
specific performance with damages is a
personal action which may be filed in a court
where any of the parties reside.33 (Citations
omitted and emphasis supplied)
G.R. No. 204970, February 01, 2016
SPOUSES CLAUDIO AND CARMENCITA
TRAYVILLA, Petitioners, v. BERNARDO
SEJAS
AND
JUVY
PAGLINAWAN,
REPRESENTED BY JESSIE PAGLINAWAN,
Respondents.

For filing an action or a permissive OR

COMPULSORY counterclaim, CROSS-CLAIM,
or money claim against an estate not based
on judgment, or for filing a third-party,
fourth-party, etc. complaint, or a complaintin-intervention, if the total sum claimed,
INCLUSIVE
OF
INTERESTS,
PENALTIES,
SURCHARGES, DAMAGES OF WHATEVER
KIND, AND ATTORNEY'S FEES, LITIGATION
EXPENSES AND COSTS and/or in cases
involving property, the FAIR MARKET value of
the REAL property in litigation STATED IN THE
CURRENT TAX DECLARATION OR CURRENT
ZONAL VALUATION OF THE BUREAU OF
INTERNAL REVENUE, WHICHEVER IS HIGHER,
OR IF THERE IS NONE, THE STATED VALUE OF
THE PROPERTY IN LITIGATION OR THE VALUE
OF THE PERSONAL PROPERTY IN LITIGATION
AS ALLEGED BY THE CLAIMANT x x x
(Emphasis supplied) shall be the basis for the
computation of the docket fees to be paid.
Since the value of the subject property as
stated in the Amended Complaint is just
P6,000.00, then the RTC did not have
jurisdiction over petitioners' case in the first
instance; it should have dismissed Civil Case
No. 4633-2K5. But it did not. In continuing to
take cognizance of the case, the trial court
clearly committed grave abuse of discretion.
G.R. No. 164594, April 22, 2015
MICHAEL SEBASTIAN, Petitioner, v.
ANNABEL LAGMAY NG, REPRESENTED BY
HER
ATTORNEY-IN-FACT,
ANGELITA
LAGMAY, Respondent.
The MCTC's jurisdiction to enforce any
settlement or arbitration .award issued by
the
Lupon.
We again draw attention to the provision of
Section 417 of the Local Government Code
that after the lapse of the six (6) month
period from the date of the settlement, the
agreement may be enforced by action in the
appropriate
city
or
municipal
court.
The law, as written, unequivocally speaks of
the "appropriate city or municipal court" as
the forum for the execution of the settlement
or arbitration award issued by the Lupon.
Notably, in expressly conferring authority

over these courts, Section 417 made no

distinction with respect to the amount
involved or the nature of the issue involved.
Thus, there can be no question that the law's
intendment was to grant jurisdiction over the
enforcement
of
settlement/arbitration
awards to the city or municipal courts
regardless of the amount. A basic principle of
interpretation is that words must be given
their literal meaning and applied without
attempted interpretation where the words of
a statute are clear,' plain and free from
ambiguity.
Section 417. Execution. - The amicable
settlement or arbitration award may be
enforced by execution by the lupon within six
(6) months from the date of the settlement.
After the lapse of such time, the settlement
may be enforced by action in the appropriate
city or municipal court.
Section 418. Repudiation. - Any party to the
dispute may, within ten (10) days from the
date of the settlement, repudiate the same
by filing with the lupon chairman a
statement to that effect sworn to before him,
where the consent is vitiated by fraud,
violence, or intimidation. Such repudiation
shall be sufficient basis for the issuance of
the certification for filing a complaint as
hereinabove provided.
FERNANDA GEONZON VDA. DE BARRERA
AND JOHNNY OCO, JR., - versus HEIRS
OF
VICENTE
LEGASPI,
REPRESENTED BY PEDRO LEGASPI,
G.R. No. 174346
Section 33 of Batas Pambansa Bilang 129,
(the Judiciary Reorganization Act of 1980), as
amended by Republic Act No. 7691 provides
for the jurisdiction of metropolitan trial
courts, municipal trial courts and municipal
circuit trial courts, to wit:
(3) Exclusive original jurisdiction in 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 Twenty
thousand pesos (P20,000.00) or, in civil
actions in Metro Manila, where such assessed

value does not exceed Fifty thousand pesos

(P50,000.00) exclusive of interest, damages
of whatever kind, attorneys fees, litigation
expenses and costs: Provided, That in cases
of land not declared for taxation purposes,
the value of such property shall be
determined by the assessed value of the
adjacent
lots.
(Emphasis,
italics
and
underscoring supplied)
Before the amendments introduced by
Republic Act No. 7691, the plenary action of
accion publiciana was to be brought before
the regional trial court.[15] With the
modifications introduced by R.A. No. 7691 in
1994, the jurisdiction of the first level courts
has been expanded to include jurisdiction
over other real actions where the assessed
value does not exceed P20,000, P50,000
where the action is filed in Metro Manila. The
first level courts thus have exclusive original
jurisdiction over accion publiciana and accion
reivindicatoria where the assessed value of
the real property does not exceed the
aforestated
amounts.
Accordingly,
the
jurisdictional element is the assessed value
of the property.
Assessed value is understood to be the worth
or value of property established by taxing
authorities on the basis of which the tax rate
is applied. Commonly, however, it does not
represent the true or market.
HEIRS OF GENEROSO SEBE vs HEIRS OF
VERONICO SEVILLA and TECHNOLOGY
AND LIVELIHOOD RESOURCE CENTER
G.R. No. 174497
The power of the RTC under Section 19 of
Batas Pambansa 129,[45] as amended,[46]
to hear actions involving title to, or
possession of, real property or any interest in
it now covers only real properties with
assessed value in excess of P20,000.00. But
the RTC retained the exclusive power to hear
actions the subject matter of which is not
capable of pecuniary estimation. Thus
SEC. 19. Jurisdiction in Civil Cases. Regional
Trial Courts shall exercise exclusive original
jurisdiction:

(1) In all civil actions in which the subject of

the litigations is incapable of pecuniary
estimation.
(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 Twenty
thousand pesos (P20,000.00) or for civil
actions in Metro Manila, where such value
exceeds Fifty thousand pesos (P50,000.00)
except actions for forcible entry into and
unlawful detainer of lands or buildings,
original jurisdiction over which is conferred
upon the Metropolitan Trial Courts, Municipal
Trial Courts, and Municipal Circuit Trial
Courts; x x x.
Section 33, on the other hand provides that,
if the assessed value of the real property
outside Metro Manila involved in the suit is
P20,000.00 and below, as in this case,
jurisdiction over the action lies in the first
level courts. Thus
SEC. 33. Jurisdiction of Metropolitan Trial
Courts, Municipal Trial Courts and Municipal
Circuit Trial Courts in Civil Cases -Metropolitan Trial Courts, Municipal Trial
Courts and Municipal Circuit Trial Courts shall
exercise:
(3) Exclusive original jurisdiction in 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 Twenty
thousand pesos (P20,000.00) or, in civil
actions in Metro Manila, where such assessed
value does not exceed Fifty thousand pesos
(P50,000.00) x x x.
[G.R. No. 149554. July 1, 2003]
SPOUSES JORGE J.
HUGUETE and
YOLANDA B. HUGUETE, petitioners, vs.
SPOUSES TEOFEDO AMARILLO EMBUDO
and
MARITES
HUGUETE-EMBUDO,
respondents.
Petitioners cause of action is based on their
right as purchaser of the 50-square meter
portion of the land from respondents. They
pray that they be declared owners of the

property sold. Thus, their complaint involved

title to real property or any interest therein.
The alleged value of the land which they
purchased was P15,000.00, which was within
the jurisdiction of Municipal Trial Court. The
annulment of the deed of sale between Ma.
Lourdes Villaber-Padillo and respondents, as
well as of TCT No. 99694, were prayed for in
the complaint because they were necessary
before the lot may be partitioned and the 50square meter portion subject thereof may be
conveyed to petitioners.
Petitioners argument that the present action
is one incapable of pecuniary estimation
considering that it is for annulment of deed
of sale and partition is not well-taken. As
stated above, the nature of an action is not
determined by what is stated in the caption
of the complaint but by the allegations of the
complaint and the reliefs prayed for. Where,
as in this case, the ultimate objective of the
plaintiffs is to obtain title to real property, it
should be filed in the proper court having
jurisdiction over the assessed value of the
property subject thereof.
G.R. No. 181622 - November 20, 2013 GENESIS INVESTMENT, INC., vs HEIRS of
CEFERINO EBARASABAL
It is true that one of the causes of action of
respondents pertains to the title, possession
and interest of each of the contending
parties over the contested property, the
assessed value of which falls within the
jurisdiction of the MTC. However, a complete
reading of the complaint would readily show
that, based on the nature of the suit, the
allegations therein, and the reliefs prayed
for, the action is within the jurisdiction of the
RTC.
This is a case of joinder of causes of action
which comprehends more than the issue of
partition of or recovery of shares or interest
over the real property in question but
includes an action for declaration of nullity of
contracts and documents which is incapable
of pecuniary estimation.

Well entrenched is the rule that jurisdiction

over the subject matter of a case is
conferred by law and is determined by the
allegations in the complaint and the
character of the relief sought, irrespective of
whether the party is entitled to all or some of
the claims asserted.

EDNA EUGENIO, MARY JEAN GREGORIO,

RENATO
PAJARILLO,
ROGELIO
VILLAMOR,versus
-STA.
MONICA
RIVERSIDE
HOMEOWNERS
ASSOCIATION,

G.R. No. 119347. March 17, 1999

EULALIA RUSSELL, RUPERTO TAUTHO,
FRANCISCO
TAUTHO,
SUSANA
T.
REALES, APITACIO TAUTHO, DANILO
TAUTHO, JUDITHA PROS, GREGORIO
TAUTHO, DEODITA T. JUDILLA, AGRIPINO
TAUTHO,
FELIX
TAUTHO,
WILLIAM
TAUTHO,
AND
MARILYN
PERALES,
petitioners, vs. HONORABLE AUGUSTINE
A.
VESTIL,
ADRIANO
TAGALOG,
MARCELO TAUTHO, JUANITA MENDOZA,
DOMINGO BANTILAN, RAUL BATALUNA
AND
ARTEMIO
CABATINGAN,
respondents.

Upon conferment of quasi-judicial functions

to
an
administrative
agency,
all
controversies relating to the subject matter
which pertain to its specialization are
deemed included within its jurisdiction.[8]
Since the HLURB is vested by law with
jurisdiction to regulate and supervise
homeowner
associations,
respondent
correctly lodged their complaint with the
HLURB. Republic Act No. 8763

Complaint filed before the Regional Trial

Court is doubtless one incapable of
pecuniary estimation and therefore within
the jurisdiction of said court.
The main purpose of petitioners in filing the
complaint is to declare null and void the
document in which private respondents
declared themselves as the only heirs of the
late spouses Casimero Tautho and Cesaria
Tautho and divided his property among
themselves to the exclusion of petitioners
who also claim to be legal heirs and entitled
to the property. While the complaint also
prays for the partition of the property, this is
just incidental to the main action, which is
the declaration of nullity of the document
above-described. It is axiomatic that
jurisdiction over the subject matter of a case
is conferred by law and is determined by the
allegations in the complaint and the
character of the relief sought, irrespective of
whether the plaintiff is entitled to all or some
of the claims asserted therein.

G.R. No. 187751

While a complaint for ejectment, which

raises the issue of who has a better right of
possession, falls within the exclusive and
original jurisdiction of first level courts, the
right of possession in the present case is,
however, necessarily intertwined with a
determination of rights and privileges under
a distinctive social housing concept such as
CMP, which falls within the expertise of the
HLURB.
The
foregoing
discussions
leave
it
unnecessary to delve on petitioners assigned
error respecting their extrajudicial and
summary eviction from the lots they occupy.
It is settled that eviction is a necessary
consequence of petitioners exclusion from
the benefits of the CMP.
CHRISTIAN GENERAL ASSEMBLY, INC.,versus - SPS. AVELINO C. IGNACIO and
PRISCILLA T. IGNACIO G.R. No. 164789
The nature of an action and the jurisdiction
of a tribunal are determined by the material
allegations of the complaint and the law
governing at the time the action was
commenced. The jurisdiction of the tribunal
over the subject matter or nature of an
action is conferred only by law, not by the
parties consent or by their waiver in favor of
a court that would otherwise have no
jurisdiction over the subject matter or the

nature of an action.Thus, the determination

of whether the CGAs cause of action falls
under the jurisdiction of the HLURB
necessitates a closer examination of the laws
defining the HLURBs jurisdiction and
authority.
Rationale for HLURBs extensive quasi-judicial
powers - The surge in the real estate
business in the country brought with it an
increasing number of cases between
subdivision
owners/developers
and
lot
buyers on the issue of the extent of the
HLURBs exclusive jurisdiction. In the cases
that reached us, we have consistently ruled
that the HLURB has exclusive jurisdiction
over complaints arising from contracts
between the subdivision developer and the
lot buyer or those aimed at compelling the
subdivision developer to comply with its
contractual and statutory obligations to
make the subdivision a better place to live in
CGA has to file its complaint before the
HLURB, the body with the proper jurisdiction.
GR NO 155113 phil Bank vs pridisons
The jurisdiction of the HLURB to regulate the
real estate trade is broad enough to include
jurisdiction over complaints for annulment of
mortgage. To disassociate the issue of nullity
of mortgage and lodge it separately with the
liquidation
court
would
only
cause
inconvenience to the parties and would not
serve the ends of speedy and inexpensive
administration of justice as mandated by the
laws vesting quasi-judicial powers in the
agency. [citations omitted] The Court thus
upholds the HLURBs jurisdiction over the
action to annul the mortgage constituted in
favor of PBComm.
G.R. No. 201781, December 10, 2014
ANNIE GERONIMO, SUSAN GERONIMO
AND SILVERLAND ALLIANCE CHRISTIAN
CHURCH*, Petitioners, v. SPS. ESTELA C.
CALDERON AND RODOLFO T. CALDERON
HLURB has jurisdiction over the present
controversy.
Jurisdiction over the subject
matter of a case is conferred by law and

determined by the allegations in the

complaint
which
comprise
a
concise
statement of the ultimate facts constituting
the plaintiffs cause of action. The nature of
an action, as well as which court or body has
jurisdiction over it, is determined based on
the allegations contained in the complaint of
the plaintiff, irrespective of whether or not
the plaintiff is entitled to recover upon all or
some of the claims asserted therein. The
averments in the complaint and the
character of the relief sought are the ones to
be consulted. Once vested by the allegations
in the complaint, jurisdiction also remains
vested irrespective of whether or not the
plaintiff is entitled to recover upon all or
some of the claims asserted therein.11We
have ruled that the jurisdiction of the HLURB
to hear and decide cases is determined by
the nature of the cause of action, the subject
matter or property involved and the parties.
The provisions of P.D. No. 957 were intended
to encompass all questions regarding
subdivisions
and
condominiums.
The
intention was aimed at providing for an
appropriate government agency, the HLURB,
to which all parties aggrieved in the
implementation of provisions and the
enforcement of contractual rights with
respect to said category of real estate may
take recourse. 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
matter. In the exercise 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.
G.R. No. 198745, January 13, 2016 BANCO
DE
ORO
UNIBANK,
INC.
(FORMERLY BANCO DE ORO-EPCI, INC.),
Petitioner,
v.
SUNNYSIDE
HEIGHTS
HOMEOWNERS
ASSOCIATION,
INC.,
Respondent.

The Court has long recognized and upheld

the rationale behind P.D. No. 957, which is to
protect innocent lot buyers from scheming
developers;34 buyers who are by law
entitled to the enjoyment of an open space
within the subdivision. Thus, this Court has
broadly construed HLURB's jurisdiction to
include complaints to annul mortgages of
condominium or subdivision units.
The jurisdiction of the HLURB to regulate the
real estate trade is broad enough to include
jurisdiction over complaints for annulment of
mortgage. To disassociate the issue of nullity
of mortgage and lodge it separately with the
liquidation
court
would
only
cause
inconvenience to the parties and would not
serve the ends of speedy and inexpensive
administration of justice as mandated by the
laws vesting quasi-judicial powers in the
agency.
GOVERNMENT SERVICE, G.R. No. 183905
INSURANCE SYSTEM,
Jurisdiction is conferred by no other source
but law. Both sides have relied upon
provisions of Rep. Act No. 8799, otherwise
known as the Securities Regulation Code
(SRC), its implementing rules (Amended
Implementing Rules or AIRR-SRC), and other
related rules to support their competing
contentions that either the SEC or the trial
courts has exclusive original jurisdiction over
the dispute.
GSIS primarily anchors its argument
on two correlated provisions of the SRC.
These are Section 53.1 and Section 20.1,
which we cite:
SEC. 53. Investigations, Injunctions and
Prosecution of Offenses . - 53.1. The
Commission may, in its discretion, make
such investigations as it deems
necessary to determine whether
any person has violated or is about
to violate any provision of this
Code, any rule, regulation or order
thereunder, or any rule of an
Exchange,
registered
securities
association, clearing agency, other

self-regulatory organization, and

may require or permit any person to file
with it a statement in writing, under
oath or otherwise, as the Commission
shall determine, as to all facts and
circumstances concerning the matter to
be investigated. The Commission may
publish information concerning any such
violations, and to investigate any
fact, condition, practice or matter
which it may deem necessary or
proper to aid in the enforcement of
the provisions of this Code, in the
prescribing of rules and regulations
thereunder,
or
in
securing
information to serve as a basis for
recommending further legislation
concerning the matters to which
this Code relates: xxx (emphasis
supplied)
SEC. 20. Proxy Solicitations.
20.1.
Proxies must be issued and proxy
solicitation must be made in accordance
with rules and regulations to be issued
by the Commission;
GSIS very well knew that the controversy
falls within the contemplation of an election
controversy properly within the jurisdiction of
the regular courts. Otherwise, it would have
never filed its original petition with the RTC
of Pasay. GSIS may have withdrawn its
petition with the RTC on a new assessment
made in good faith that the controversy falls
within the jurisdiction of the SEC, yet the
reality is that the reassessment is precisely
wrong as a matter of law.

G.R. No. 187702

October 22,
2014
SECURITIES
AND
EXCHANGE
COMMISSION,
Petitioner,
vs.
THE
HONORABLE
COURT
OF
APPEALS,
OMICO CORPORATION, EMILIO S. TENG
AND TOMMY KIN HING TIA, Respondents

The conferment of original and exclusive

jurisdiction on the regular courts over such
controversies in the election of corporate
directors must be seen as intended to
confine to one body the adjudication of all
related claims and controversy arising from
the election of such directors. For that
reason, the aforequoted Section 2, Rule 6 of
the Interim Rules broadly defines the term
"election contest" as encompassing all
plausible incidents arising from the election
of corporate directors, including: (1) any
controversy or dispute involving title or claim
to any elective office in a stock or nonstock
corporation, (2) the validation of proxies, (3)
the manner and validity of elections and (4)
the qualifications of candidates, including the
proclamation of winners. If all matters
anteceding the holding of such election
which affectits manner and conduct, such as
the proxy solicitation process, are deemed
within the original and exclusive jurisdiction
of the SEC, then the prospect of overlapping
and competing jurisdictions between that
body and the regular courts becomes
frighteningly real. From the languageof
Section 5 (c) of Presidential Decree No. 902A, it is indubitable that controversies as to
the qualification of voting shares, or the
validity of votes cast in favor of a candidate
for election to the board of directors are
properly cognizable and adjudicable by the
regular courts exercising original and
exclusive jurisdiction over election cases. x x
x.
The ruling harmonizes the seeming conflict
between
the
Amended
SRC
Rules
promulgated by the SEC and the Interim
Rules of Procedure Governing Intra-Corporate
Disputes promulgated by the Court.
G.R. No. 181416
November 11,
2013
MEDICAL
PLAZA
MAKATI
CONDOMINIUM CORPORATION, Petitioner,
vs. ROBERT H. CULLEN, Respondent.
An intra-corporate controversy is one which
pertains to any of the following relationships:
(1) between the corporation, partnership or
association and the public; (2) between the
corporation, partnership or association and

the State insofar as its franchise, permit or

license to operate is concerned; (3) between
the corporation, partnership or association
and its stockholders, partners, members or
officers; and (4) among the stockholders,
partners or associates themselves.22 Thus,
under the relationship test, the existence of
any of the above intra-corporate relations
makes the case intra-corporate.
Under the nature of the controversy test,
"the controversy must not only be rooted in
the
existence
of
an
intra-corporate
relationship, but must as well pertain to the
enforcement of the parties correlative rights
and obligations under the Corporation Code
and
the
internal
and
intra-corporate
regulatory rules of the corporation."In other
words, jurisdiction should be determined by
considering both the relationship of the
parties as well as the nature of the question
involved
condominium corporations are not covered
by the amendment. Thus, the intra-corporate
dispute between petitioner and respondent is
still within the jurisdiction of the RTC sitting
as a special commercial court and not the
HLURB. The doctrine laid down by the Court
in
Chateau
de
Baie
Condominium
Corporation v. Moreno which in turn cited
Wack Wack Condominium Corporation, et al
v. CA is still a good law.
G.R. No. 203678, February 17, 2016
CONCORDE vs UGUSTO H. BACULIO;
NEW
PPI
CORPORATION;
ASIAN
SECURITY AND INVESTIGATION AGENCY
AND ITS SECURITY GUARDS
Having clearly settled that as courts of
general jurisdiction, the designated Special
Commercial Courts and the regular RTCs are
both conferred by law the power to hear and
decide civil cases in which the subject of the
litigation
is
incapable
of
pecuniary
estimation, such as an action for injunction,
the Court will now examine the material
allegations in the petition for injunction with
damages, in order to determine whether
Branch 149 of the Makati RTC has jurisdiction
over the subject matter of the case.

For further guidance, the Court finds it apt to

point out that the same principles apply to
the inverse situation of ordinary civil cases
filed before the proper RTCs but wrongly
raffled to its branches designated as Special
Commercial Courts. In such a scenario, the
ordinary civil case should then be referred to
the Executive Judge for re-docketing as an
ordinary civil case; thereafter, the Executive
Judge should then order the raffling of the
case to all branches of the same RTC, subject
to limitations under existing internal rules,
and the payment of the correct docket fees
in case of any difference. Unlike the limited
assignment/raffling of a commercial case
only to branches designated as Special
Commercial Courts in the scenarios stated
above, the re-raffling of an ordinary civil case
in this instance to all courts is permissible
due to the fact that a particular branch which
has
been
designated
as
a
Special
Commercial Court does not shed the RTCs
general jurisdiction over ordinary civil cases
under the imprimatur of statutory law, i.e.,
Batas Pambansa Bilang (BP 129). To restate,
the designation of Special Commercial Courts
was merely intended as a procedural tool to
expedite the resolution of commercial cases
in line with the court's exercise of
jurisdiction. This designation was not made
by statute but only by an internal Supreme
Court rule under its authority to promulgate
rules governing matters of procedure and its
constitutional mandate to supervise the
administration of all courts and the
personnel thereof. Certainly, an internal rule
promulgated by the Court cannot go beyond
the commanding statute. But as a more
fundamental reason, the designation of
Special Commercial Courts is, to stress,
merely an incident related to the court's
exercise of jurisdiction, which, as first
discussed, is distinct from the concept of
jurisdiction over the subject matter. The RTCs
general jurisdiction over ordinary civil cases
is therefore not abdicated by an internal rule
streamlining court procedure.
G.R. No. 183923
November 27,
2013 GENEROSO ENESIO, Petitioner, vs.
LILIA TULOP, substituted by her heirs,
namely: MILAGROS T. ASIA, MATTHEW

N. TULOP and RESTITUTO N. TULOP, JR.,

Respondents.
In Bayog, the Court faulted the Municipal
Circuit Trial Court (MCTC) for not receiving
the defendants belated Answer. As ruled by
the Court, had the MCTC not refrained from
receiving the defendants Answer, the MCTC
would have found that the defendant raised
tenancy as an issue. While tenancy as a
defense in ejectment cases does not
automatically divest the MCTC of its
jurisdiction over ejectment cases, the MCTC
should have heard and received evidence to
determine whether the MCTC had jurisdiction
over the case. If tenancy had indeed been an
issue, the MCTC had no option but to dismiss
the case for lack of jurisdiction.10
In the present case, the MTC correctly
observed the proper procedure in ejectment
cases. As expressly provided in the Revised
Rules on Summary Procedure, ejectment
cases merely require the submission by the
parties of affidavits and position papers. The
rule directs courts to conduct hearings only
when necessary to clarify factual matters.
"This procedure is in keeping with the
objective of the Rule of promoting the
expeditious and inexpensive determination
of cases."11
Therefore, the petitioners assertion that the
MTC did not receive testimonial or
documentary evidence in resolving the case
is not correct. In fact, it is from the evidence
furnished by the parties that the MTC
concluded that the petitioner never shared
his produce with Lilia. Expectedly, the MTC
ruled that the petitioner was not Lilias
tenant and in this light, it had jurisdiction
over the case
ARTEMIO
INIEGOversus
-The
HONORABLE
JUDGE
GUILLERMO
G.
PURGANAN, in his official capacity as
Presiding Judge of the Regional Trial
Court, Branch 42, City of Manila, and
FOKKER C. SANTOS
G. R. No. 166876

Actions for damages based on quasi-delicts

are actions that are capable of pecuniary
estimation. As such, they fall within the
jurisdiction of either the RTC or the municipal
courts, depending on the amount of
damages claimed. In this case, the amount
of damages claimed is within the jurisdiction
of the RTC, since it is the claim for all kinds of
damages that is the basis of determining the
jurisdiction of courts, whether the claims for
damages arise from the same or from
different causes of action.
IRENE SANTE AND REYNALDO SANTE, versus - HON. EDILBERTO T. CLARAVALL,
in his capacity as Presiding Judge of
Branch 60, Regional Trial Court of
Baguio City, and VITA N. KALASHIAN,
G.R. No. 173915
RTC had jurisdiction over the case.
Lastly, we find no error, much less
grave abuse of discretion, on the part of the
Court of Appeals in affirming the RTCs order
allowing the amendment of the original
complaint
from
P300,000.00
to
P1,000,000.00 despite the pendency of a
petition for certiorari filed before the Court of
Appeals. While it is a basic jurisprudential

principle that an amendment cannot be

allowed when the court has no jurisdiction
over the original complaint and the purpose
of the amendment is to confer jurisdiction on
the court, here, the RTC clearly had
jurisdiction over the original
complaint and amendment of the complaint
was then still a matter of right
Jurisprudential principle that an amendment
cannot be allowed when the court has no
jurisdiction over the original complaint and
the purpose of the amendment is to confer
jurisdiction on the court, here, the RTC
clearly had jurisdiction over the original
complaint and amendment of the complaint
was then still a matter of right