LA NAVAL DRUG CORP.

v CA

FACTS: In 1989, a conflict between La Naval Drug Corporation and a certain Wilson Yao arose regarding a lease
contract. Yao invoked a provision in the lease contract whereby pursuant to R.A. 876 (Arbitration Law), they should refer
the matter to arbitration. Hence, the parties agreed to refer the issue to three arbitrators however, certain complications
arose when they were choosing a third arbitrator. This prompted Yao to go to court to demand the arbitrators to proceed
with the arbitration. Yao went to the regional trial court (Angeles City) and the case was filed as a summary proceeding
case under R.A. 876. Yao also prayed for an award for damages in his favor.
In its answer, La Naval asserted that the case should be dismissed as it was filed prematurely; La Naval questioned Yao’s
claim for damages as it averred that the same should be litigated independently and not in the same summary proceeding
case. However, La Naval also posed a counterclaim.
The RTC resolved the matter regarding the arbitrators (it appointed a third arbitrator). The RTC also ruled that La Naval is
estopped from questioning Yao’s claim for damages for being out of jurisdiction as La Naval itself filed a counterclaim for
damages.

ISSUE: Whether or not the RTC has jurisdiction over the claims for damages between parties.

HELD: No. R.A. 876 is clear that summary proceedings under said law shall only involve the matter of arbitration. The
parties’ claims for damages must be litigated in another civil case.

The Supreme Court went on to discuss that where the court clearly has no jurisdiction over the subject matter, in this case
the claim and counterclaim for damages, the court must dismiss the case (in this case, the claim and counterclaim for
damages). Lack of jurisdiction over the subject matter as a defense may be raised at any time. Failure to raise such
defense shall not estop the defendant from raising such defense (as opposed to the defense of lack of jurisdiction over the
person which is deemed waived if the defendant voluntarily appeared – if defendant voluntarily appeared, then he is
estopped from raising that defense).

ATWELL v Concepcion Progressive Asso Inc.

Facts:
Emiliano Melgazo founded and organized Concepcion Progressive Association (CPA) and in its behalf bought a parcel of
land to be converted to a wet market, to generate income which were mostly rentals paid to CPA. When he died, his son
petitioner Manuel Melgazo succeeded him as President and other petitioners as officers and they started to process the
registering of CPA as a stock corporation. Meanwhile, the other elected officers and members formed their own group and
registered themselves in SEC as officers and members of respondent CPAI. The petitioners were not listed either as
members or officers and respondent CPAI objected when they made collection of the rental payments. CPAI filed a case
in SEC for mandatory injunction but with the passage of RA 8799, was transferred to a special commercial court.
Petitioners contend that since they were not CPAI members the case did not involve intra-corporate dispute to warrant the
jurisdiction of the commercial court.

Issue:
Whether or not there is intra-corporate dispute to warrant the jurisdiction of the special commercial court.

Ruling: NO.
To determine whether a case involves an intra-corporate controversy to be heard and decided by the RTC, two elements
must concur:
(1) the status or relationship of the parties and
(2) the nature of the question that is subject of their controversy.
The first element requires that the controversy must arise out of intra-corporate or partnership relations: (a) between any
or all of the parties and the corporation, partnership or association of which they are stockholders, members or
associates; (b) between any or all of them and the corporation, partnership or association of which they are stockholders,
members or associates and (c) between such corporation, partnership or association and the State insofar as it concerns
their individual franchises. On the other hand, the second element requires that the dispute among the parties be
intrinsically connected with the regulation of the corporation. If the nature of the controversy involves matters that are
purely civil in character, necessarily, the case does not involve an intra-corporate controversy.
In the case at bar, these elements are not present. The records reveal that petitioners were never officers nor members of
CPAI. CPAI itself admitted this in its pleadings. In fact, petitioners were the only remaining members of CPA which,
obviously, was not the CPAI that was registered in the SEC.
Moreover, the issue in this case does not concern the regulation of CPAI (or even CPA). The determination as to who is
the true owner of the disputed property entitled to the income generated therefrom is civil in nature and should be
threshed out in a regular court. Cases of this nature are cognizable by the RTC under BP 129. Therefore, the conflict
among the parties here was outside the jurisdiction of the special commercial court.
Figueroa vs. People
CASE SUMMARY
RTC Bulacan convicted petitioner for reckless imprudence resulting to homicide. On appeal to the CA, he challenged for
the first time the jurisdiction of the RTC. The CA held that he actively participated in the trial and raised the jurisdictional
issue belatedly, so he was already estopped by laches.
First, the Court cited all its previous cases on estoppel by laches relating to attacks on jurisdiction. Ultimately, the
SC held that Figueroa may still attack the jurisdiction of the RTC on appeal. The general rule remains: a court's lack of
jurisdiction may be raised at any stage of the proceedings, even on appeal. The reason is that jurisdiction is conferred by
law, and lack of it affects the very authority of the court to take cognizance of and to render judgment on the action.
Moreover, jurisdiction is determined by the averments of the complaint, not by the defenses contained in the answer.
Since jurisdiction of a court over the subject-matter of the action is a matter of law, it may not be conferred by
consent or agreement of the parties. The lack of jurisdiction of a court may be raised at any stage of the proceedings,
even on appeal.
In applying the principle of estoppel by laches in the exceptional case of Sibonghanoy, the Court therein
considered the patent and revolting inequity and unfairness of having the judgment creditors have to go through the
troubles of the case once more after more or less 15 years. The same, however, does not obtain in the instant case.
In this case, petitioner is not estopped by laches in attacking the jurisdiction of the RTC, since no considerable
period had yet elapsed for laches to attach.

DOCTRINE
Jurisdiction of a court over the subject-matter of the action is a matter of law and may not be conferred by consent or
agreement of the parties. The lack of jurisdiction of a court may be raised at any stage of the proceedings, even on
appeal.
Further, estoppel, being in the nature of a forfeiture, is not favored by law. It is to be applied rarely—only from
necessity, and only in extraordinary circumstances. The doctrine must be applied with great care and the equity must be
strong in its favor. When misapplied, the doctrine of estoppel may be a most effective weapon for the accomplishment of
injustice. Moreover, a judgment rendered without jurisdiction over the subject matter is void.
Hence, the Revised Rules of Court provides for remedies in attacking judgments rendered by courts or tribunals
that have no jurisdiction over the concerned cases. No laches will even attach when the judgment is null and
void for want of jurisdiction

Samar II Electronic Cooperative vs. Seludo, Jr. (GR 173840)

It may not be amiss to reiterate the prevailing rule that the doctrine of primary jurisdiction applies where a claim is
originally cognizable in the courts and comes into play whenever enforcement of the claim requires the resolution of
issues which, under a regulatory scheme, has been placed within the special competence of an administrative agency. In
such a case, the court in which the claim is sought to be enforced may suspend the judicial process pending referral of
such issues to the administrative body for its view or, if the parties would not be unfairly disadvantaged, dismiss the case
without prejudice.
Corollary to the doctrine of primary jurisdiction is the principle of exhaustion of administrative remedies. The Court, in a
long line of cases, has held that before a party is allowed to seek the intervention of the courts, it is a pre-condition that he
avail himself of all administrative processes afforded him. Hence, if a remedy within the administrative machinery can be
resorted to by giving the administrative officer every opportunity to decide on a matter that comes within his jurisdiction,
then such remedy must be exhausted first before the courts power of judicial review can be sought. The premature resort
to the court is fatal to ones cause of action. Accordingly, absent any finding of waiver or estoppel, the case may be
dismissed for lack of cause of action.
The doctrines of primary jurisdiction and exhaustion of administrative remedies are subject to certain exceptions, to wit:
(a) where there is estoppel on the part of the party invoking the doctrine; (b) where the challenged administrative act is
patently illegal, amounting to lack of jurisdiction;
(c) where there is unreasonable delay or official inaction that will irretrievably prejudice the complainant;
(d) where the amount involved is relatively so small as to make the rule impractical and oppressive;
(e) where the question involved is purely legal and will ultimately have to be decided by the courts of justice;
(f) where judicial intervention is urgent;
(g) where the application of the doctrine may cause great and irreparable damage;
(h) where the controverted acts violate due process;
(i) where the issue of non-exhaustion of administrative remedies has been rendered moot;
(j) where there is no other plain, speedy and adequate remedy;
k) where strong public interest is involved; and (l) in quo warranto proceedings
BELLE CORP vs. ERLINDA DE LEON, et. Al

FACTS:

Plaintiffs-appellants herein respondents Erlinda Banks, Rhodora Tiatco, Betty Torres, Gregorio De Leon, Alberto De Leon,
Eufronio De Leon, Jr. and defendant-appellee Nelia Alleje were seven of the eight children of the late spouses Eufronio
and Josefa De Leon, while plaintiff Maria Eliza De Grano also one of herein respondents was the daughter and sole heir
of the late Angelina De Leon-De Grano, the eighth child. Defendant-appellee Alfredo Alleje was the husband of Nelia De
Leon-Alleje (both hereinafter referred to as SPOUSES ALLEJE), both of whom were the principal stockholders and
officers of defendant-appellee Nelfred Properties Corporation (NELFRED). The disputed property was a 13.29 hectare
parcel of unregistered land originally belonging to the late spouses Eufronio and Josefa. On February 9, 1979, a Deed of
Absolute Sale (1979 DEED) was executed between the LATE SPOUSES and NELFRED, represented therein by Nelia,
wherein ownership of the property was conveyed to Nelia for P 60,000.00 and was thereafter registered with the Register
of Deeds. Herein petitioner BELLE, on one hand, and NELFRED and SPOUSES ALLEJE on the other executed a
Contract to Sell covering the disputed property. Deed of Absolute Sale (1998 DEED) was executed on June 24, 1998
between BELLE and NELFRED wherein the latter transferred ownership of the disputed property to the former.
Meanwhile, on January 19, 1998, respondents filed a Complaint for "Annulment of Deed of Sale, Reconveyance of
Property with Prayer for Issuance of a Writ of Preliminary Injunction and Damages" against the SPOUSES ALLEJE,
NELFRED and BELLE wherein they sought the annulment of the Contract to Sell. On February 9, 1998, BELLE filed a
Motion to Dismiss wherein it alleged that the Complaint stated no cause of action against BELLE, which was an innocent
purchaser for value. RTC dismissed the Complaint against BELLE for failure to state a cause of action on the ground that
there was no allegation in the Complaint that BELLE was a purchaser in bad faith. Herein respondents then filed a Motion
for Reconsideration. On November 11, 1998, pending the resolution of their Motion for Reconsideration of the September
23, 1998 Order, herein respondents filed a Manifestation/Motion to admit their Amended Complaint and at the same time,
the RTC admitted the Amended Complaint of the plaintiffs-appellants. BELLE filed a "Motion for Reconsideration or to
Dismiss the Amended Complaint" wherein it alleged that the Amended Complaint still stated no cause of action. RTC
reconsidered its Order and lifted the dismissal against BELLE. Aggrieved by the Order of the RTC, respondents filed an
appeal with the CA. CA, reversed and set aside RTC order. Hence, this petition for review on certiorari.

ISSUE: WON cause of action exists to warrant the right of herein respondents to sue against BELLE.

RULING: The essential elements of a cause of action are (1) a right in favor of the plaintiff by whatever means and under
whatever law it arises or is created; (2) an obligation on the part of the named defendant to respect or not to violate such
right; and (3) an act or omission on the part of such defendant in violation of the right of the plaintiff or constituting a
breach of the obligation of the defendant to the plaintiff for which the latter may maintain an action for recovery of
damages or other appropriate relief. In determining whether a complaint states a cause of action, the RTC can consider
all the pleadings filed, including annexes, motions, and the evidence on record. The focus is on the sufficiency, not the
veracity, of the material allegations. Moreover, the complaint does not have to establish facts proving the existence of a
cause of action at the outset; this will have to be done at the trial on the merits of the case. It is evident from the
allegations in the Amended Complaint that respondents specifically alleged that they are owners of the subject property
being held in trust by their sister, Nelia Alleje, and that petitioner acted in bad faith when it bought the property from their
sister, through her company, Nelfred, knowing that herein respondents claim ownership over it. The Court, thus, finds no
error on the part of the CA in ruling that the allegations in the complaint are sufficient to establish a cause of action for the
nullification of the sale of the subject property to herein petitioner.

City of Bacolod v San Miguel

Facts:
The city of Bacolod passed an ordinance imposing upon manufacture corporations engaged in bottling of soft drinks a fee
of 1/24 of a centavo, plus 2% surcharge every month, but in no case exceeding 24% for one year for delinquent payers;
The fee was increased from 1/24 (0.01 cents) to 1/8 (0.03 cents). Respondent refused to pay so petitioner filed a case
against it at the CFI Negros Occ., where the latter prayed for the payment of the fee, but without mention of the
surcharge;
Respondent lost in the CFI and so it raised the constitutionality of the ordinance before the SC where the SC upheld its
constitutionality and affirmed the CFI decision;
Failing to collect the surcharge, however, petitioner filed another case before the CFI for the collection of the surcharge;

Lower court decisions:

CFI: ordered the respondent to pay the surcharge, denied reconsideration
*SC directly

Issue: WON there is a splitting of cause of action

Ruling: Yes, there is a splitting of cause of action.

For a single cause of action or violation of a right, the plaintiff may be entitled to several reliefs. It is the filing of separate
complaints for these several reliefs that constitutes splitting of action.

At bar, when respondent failed and refused to pay the difference in bottling charges, it violated the right of petitioner, thus
the latter being entitled to two reliefs: (1) recovery of basic charges; and (2) payment of corresponding surcharge, the
latter being merely a consequence of the failure to pay the former. In other words, the obligation of respondent to pay the
surcharges arose from the violation by it of the same right of the petitioner from which the obligation to pay the basic
charges also arose. Upon these facts, it is obvious that petitioner has filed separate complaints for each of the two reliefs
related to the same single cause of action, thereby splitting up the said cause of action.

Jalandoni v Martir-Guanzon

FACTS: The appellant spouses began a suit against the appellees Antonio Guanzon, et. al., for

 partition of lots of the the Murcia Cadastre, as well the Bogo Cadastre

 damages caused by the defendants' refusal to recognize plaintiffs' right

 partition said lots

 deliver plaintiff's share in the crops

CFI of Negros Occidental held for plaintiffs and ordered the partition of the lands, but denied their claim for damages
because of failure to "prove the exact and actual damages suffered by them.

The decision having become final because none of the parties appealed therefrom, the plaintiffs instituted the present
action, seeking recovery from the defendants damages. 1) P20,000 as moral and exemplary damages due to suffering,
anguish and anxiety occasioned by the defendant's refusal to partition of the properties involved in the proceeding case;
(2) P55,528.20 as share of the products of the property (3) P4,689.54 as land taxes due unpaid on the properties
involved; and (4) P2,500 for attorney's fees.

Upon motion of defendant's, the court dismissed the second complaint for failure to state a cause of action; and after their
motion to reconsider was denied, plaintiffs appealed to this Court.

ISSUE: Whether or not the plaintiffs have the right to file an action for damages despite the decision being final.

HELD: No

RATIO: SC finds the dismissal to have been correctly entered. Except as concomitant to physical injuries, moral and
corrective damages were not recoverable under the Civil Code of 1899 which was the governing law at the time.
Recovery of such damages was established for the first time in 1950 by the new Civil Code, and action not be made to
apply retroactively to acts that occurred character of these damages.

As to the value of the plaintiff's share in the products of the land, their recovery is now barred by the previous
judgment. These damages are but the result of the original cause of action, viz., the continuing refusal by defendants in
1941 to recognize the plaintiffs' right to an interest in the property. In the same way that plaintiffs claimed for their share of
the produce from 1941 to 1947, these later damages could have been claimed in the first action, either in the original
complaint (for their existence could be anticipated when the first complaint was filed) or else by supplemental plaeding. To
allow them to be recovered by subsequent suit would be a violation of the rule against multiplicity of suits , and
specifically of sections 3 and 4 of Rules 2 of the Rules of Court, against the splitting of causes of action, since
these damages spring from the same cause of action that was pleading in the former case between the same parties
That the former judgment did not touch upon these damages is not material to its conclusive effect; between the same
parties, with the same subject matter and cause of action, a final judgment on the merits is conclusive not only the
questions actually contested and determined, but upon all matters that might have been litigated and decided in the
former suit, i.e., all matters properly belonging to the subject of the controversy and within the scope of the issue Hence,
the rejection of plaintiffs' claim for damages in Case No. 573 imports denial of those who claimed, since there are a mere
continuation of the former.

Annent the land taxes allegedly overdue and unpaid, it is readily apparent that, taxes beein due to the government,
plaintiffs have no right to compel payment thereof to themselves. The case could be otherwise if plaintiffs had paid the
taxes to stave of forfeiture of the common property of tax delinquency; in that event, they could compel contribution. But
the complaint does not aver any such tax payment.

Little need be said concerning the claim for attorney's fees under the fourth cause of action. If they be fees for the lawyer's
services in the former case, they are barred from recovery for the reasons already given; if for services in the present
case, there is no jurisdiction therefor, since no case is made out for the plaintiffs.

Rule 2:
Section 1. Ordinary civil actions, basis of. – Every ordinary civil action must be based on a cause of action.
Section 2. Cause of action, defined. – A cause of action is the act or omission by which a party violates a right of
another.
Section 3. One suit for a single cause of action. – A party may not institute more than one suit for a single cause of
action.
Section 4. Splitting a single cause of action; effect of. – If two or more suits are instituted on the basis of the same
cause of action, the filing of one or a judgment upon the merits in any one is available as a ground for the dismissal of the
others.
Section 5. Joinder of causes of action. – A party may in one pleading assert, in the alternative or otherwise, as many
causes of action as he may have against an opposing party, subject to the following conditions:
(a) The party joining the causes of action shall comply with the rules on joinder of parties;
(b) The joinder shall not include special civil actions or actions governed by special rules;
(c) Where the causes of action are between the same parties but pertain to different venues or jurisdictions, the joinder
may be allowed in the Regional Trial Court provided one of the causes of action falls within the jurisdiction of said court
and the venue lies therein; and
(d) Where the claims in all the causes of action are principally for recovery of money, the aggregate amount claimed shall
be the test of jurisdiction.
Section 6. Misjoinder of causes of action. – Misjoinder of causes of action is not a ground for dismissal of an action. A
misjoined cause of action may, on motion of a party or on the initiative of the court, be severed and proceeded with
separately.

Joseph v. Bautista, 170 SCRA 540 (’89)

FACTS: Joseph was a paying passenger in a cargo truck. The cargo truck tried to overtake a tricycle proceeding in the
same direction. At the same time, a pick-up truck tried to overtake the cargo truck, thus the cargo truck was forced to veer
towards the shoulder of the road & rammed a mango tree in the process. Joseph sustained a bone fracture in one of his
legs. Joseph sued the owner of the cargo truck for breach of the contract of carriage & the owner of the pick-up for quasi-
delict for injuries he sustained. The owner of the pick-up paid Joseph the amount he was claiming thru a settlement
agreement. Joseph still wants to maintain the action vs. the truck owner claiming that he still has another cause of action
vs. the latter, for breach of contract of carriage.

HELD: When there is only one delict or wrong (i.e. one injury), there is only one cause of action regardless of the number
of rights that may have been violated belonging to one person (violation of contract of carriage & quasi-delict).
The singleness of a cause of action lies in the singleness of the delict or wrong violating the rights of one person.
Nevertheless, if only one injury resulted fr. several acts, only 1 cause of action arises. In this case, the petitioner
sustained a single injury on his person. That vested in him a single cause of action, albeit w/ the correlative rights of
action vs. the different respondents thru appropriate remedies allowed by law.
The resps. having been found to be solidarily liable to the pet., the full payment made by some of the solidary debtors &
their subsequent release fr. any & all liability to pet. inevitably resulted in the extinguishment & release fr. liability of other
solidary debtors.