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In many cases,[89] this Court has time and time again reminded magistrates to
heed the demand of Section 14, Article VIII of the Constitution. The Court,
through Chief Justice Hilario G. Davide Jr. in Yao v. Court of Appeals,
[90]
discussed at length the implications of this provision and strongly exhorted
thus:
Faithful adherence to the requirements of Section 14, Article VIII of the
Constitution is indisputably a paramount component of due process and fair
play. It is likewise demanded by the due process clause of the Constitution. The
parties to a litigation should be informed of how it was decided, with an
explanation of the factual and legal reasons that led to the conclusions of the
court. The court cannot simply say that judgment is rendered in favor of X and
against Y and just leave it at that without any justification whatsoever for its
action. The losing party is entitled to know why he lost, so he may appeal to the
higher court, if permitted, should he believe that the decision should be
reversed. A decision that does not clearly and distinctly state the facts and the
law on which it is based leaves the parties in the dark as to how it was reached
and is precisely prejudicial to the losing party, who is unable to pinpoint the
possible errors of the court for review by a higher tribunal. More than that, the
requirement is an assurance to the parties that, in reaching judgment, the judge
did so through the processes of legal reasoning. It is, thus, a safeguard against
the impetuosity of the judge, preventing him from deciding ipse dixit.Vouchsafed
neither the sword nor the purse by the Constitution but nonetheless vested with
the sovereign prerogative of passing judgment on the life, liberty or property of
his fellowmen, the judge must ultimately depend on the power of reason for
sustained public confidence in the justness of his decision.
case to the labor arbiter for immediate appropriate proceedings. Petitioner then
filed a motion for reconsideration which was denied by the NLRC in its resolution
dated August 18, 1997 for lack of merit, hence the present petition alleging that
the NLRC committed grave abuse of discretion.
ISSUE-WON the SC should entertain the present petition
HELD-NO (should be remanded to CA)
Ratio. All references in the amended Sec 9 of BP No. 129 to supposed appeals
from the NLRC to the SC are interpreted and hereby declared to mean and refer
to petitions for certiorari under Rule 65. Consequently, all such petitions should
henceforth be initially filed in the CA in strict observance of the doctrine on the
hierarchy of courts as the appropriate forum for the relief desired.
Reasoning. It will be noted that paragraph (3), Section 9 of B.P. No. 129 now
grants exclusive appellate jurisdiction to the Court of Appeals over all final
adjudications of the Regional Trial Courts and the quasi-judicial agencies
generally or specifically referred to therein except, among others, "those falling
within the appellate jurisdiction of the Supreme Court in accordance with . . . the
Labor Code of the Philippines under Presidential Decree No. 442, as amended, .
. . ." This would necessarily contradict what has been ruled and said all along
that appeal does not lie from decisions of the NLRC. Yet, under such excepting
clause literally construed, the appeal from the NLRC cannot be brought to the
Court of Appeals, but to this Court by necessary implication.
The same exceptive clause further confuses the situation by declaring that the
Court of Appeals has no appellate jurisdiction over decisions falling within the
appellate jurisdiction of the Supreme Court in accordance with the Constitution,
the provisions of B.P. No. 129, and those specified cases in Section 17 of the
Judiciary Act of 1948. These cases can, of course, be properly excluded from
the exclusive appellate jurisdiction of the Court of Appeals. However, because of
the aforementioned amendment by transposition, also supposedly excluded are
cases falling within the appellate jurisdiction of the Supreme Court in
accordance with the Labor Code. This is illogical and impracticable, and
Congress could not have intended that procedural gaffe, since there are no
cases in the Labor Code the decisions, resolutions, orders or awards wherein
are within the appellate jurisdiction of the Supreme Court or of any other court
for that matter.
-Incidentally, it was noted by the sponsor therein that some quarters were of the
opinion that recourse from the NLRC to the Court of Appeals as an initial step in
the process of judicial review would be circuitous and would prolong the
proceedings. On the contrary, as he commendably and realistically emphasized,
that procedure would be advantageous to the aggrieved party on this reasoning:
i.e., , to allow these cases to be appealed to the Court of Appeals would give
litigants the advantage to have all the evidence on record be reexamined and
reweighed after which the findings of facts and conclusions of said bodies are
correspondingly affirmed, modified or reversed.
-Under such guarantee, the Supreme Court can then apply strictly the axiom
that factual findings of the Court of Appeals are final and may not be reversed on
appeal to the Supreme Court. A perusal of the records will reveal appeals which
are factual in nature and may, therefore, be dismissed outright by minute
resolutions.
-While the SC does not wish to intrude into the Congressional sphere on the
matter of the wisdom of a law, on this score it adds the further observations that
there is a growing number of labor cases being elevated to this Court which, not
being a trier of fact, has at times been constrained to remand the case to the
NLRC for resolution of unclear or ambiguous factual findings; that the Court of
Appeals is procedurally equipped for that purpose, aside from the increased
number of its component divisions; and that there is undeniably an imperative
need for expeditious action on labor cases as a major aspect of constitutional
protection to labor.
-This case therefore, reiterate the judicial policy that the Supreme Court will not
entertain direct resort to it unless the redress desired cannot be obtained in the
appropriate courts or where exceptional and compelling circumstances justify
availment of a remedy within and calling for the exercise of its primary
jurisdiction.
ISSUE -WON the RTC has jurisdiction to entertain the civil case.
RUSSELL V VESTIL
304 SCRA 738/KAPUNAN; March 17, 1999
NATURE-Petition for Certiorari
FACTS
- Petitioners filed a complaint against respondents, denominated
"DECLARATION OF NULLITY AND PARTITION," with the RTC of Mandaue City
- The complaint alleged that petitioners are co-owners of that parcel of land in
Liloan, Cebu. The land was previously owned by the spouses Casimero Tautho
and Cesaria Tautho.
- Upon the death of said spouses, the property was inherited by their legal heirs,
herein petitioners and private respondents. Since then, the lot had remained
HELD -YES.
Ratio Singsong vs. Isabela Sawmill: In determining whether an action is one the
subject matter of which is not capable of pecuniary estimation this Court has
adopted the criterion of first ascertaining the nature of the principal action or
remedy sought. If it is primarily for the recovery of a sum of money, the claim is
considered capable of pecuniary estimation, and whether jurisdiction is in the
municipal courts or in the courts of first instance would depend on the amount of
the claim. However, where the basic issue is something other than the right to
recover a sum of money, where the money claim is purely incidental to, or a
consequence of, the principal relief sought, this Court has considered such
actions as cases where the subject of the litigation may not be estimated in
terms of money, and are cognizable exclusively by courts of first instance
Examples of actions incapable of pecuniary estimation are those for specific
performance, support, or foreclosure of mortgage or annulment of judgment;
also actions questioning the validity of a mortgage, annulling a deed of sale or
conveyance and to recover the price paid and for rescission, which is a
counterpart of specific performance.
While actions under Sec. 33(3) of B.P. 129 are also incapable of pecuniary
estimation, the law specifically mandates that they are cognizable by the MTC,
METC, or MCTC where the assessed value of the real property involved does
exceed P20,000.00 in Metro Manila, or P50,000.00, if located elsewhere. If the
value exceeds P20,000.00 or P50,000.00 as the case may be, it is the Regional
Trial Courts which have jurisdiction under Sec. 19(2).
Reasoning The subject matter of the complaint in this case is annulment of a
document denominated as "DECLARATION OF HEIRS AND DEED OF
CONFIRMATION OF PREVIOUS ORAL PARTITION." 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. Disposition
The petition was GRANTED.
De Ungria et al. vs. Court of Appeals
G.R. No. 165777 | July 25, 2011
FACTS
This is a petition for review on certiorari for ownership, possession and
damages, and alternative causes of action either to declare two documents as
patent nullities, and/or for recovery of Rosario's conjugal share with damages or
redemption of the subject land against petitioner Ceferina de Ungria et al.
Respondent Rosario is the surviving wife of the late Fernando Castor, while the
rest of the respondents are their legitimate children.
The documents they (respondents) sought to annul are (1) the Deed of Transfer
of Rights and Interest including Improvements thereon allegedly executed by
Fernando in favor of Eugenio de Ungria, petitioner's father; and (2) the Affidavit
of Relinquishment executed by Eugenio in favor of petitioner.
Petitioner also filed an Addendum to the Motion to Dismiss raising, among
others that the court has non jurisdiction over the case for failure of plaintiffs to
pay the filing fee in full. Pending resolution of the motion, respondents filed a
Motion to Allow them to continue prosecuting this case as indigent litigants.
Pascual vs. Court of Appeals (339 SCRA 117) July 27, 2010
also payment of unpaid and outstanding rentals. MTC's dismissing the complaint
was properly decreed, Petition for review is granted.
Held: Pursuant to R.A. 8799, 5.2, which took effect on August 8, 2000, the
jurisdiction of the Sec to decide cases involving intra-corporate dispute was
transferred to courts of general jurisdiction. Thus, the question as to whether this
case involves an intra-corporate dispute is now only of academic interest. Even
if the case involves an intra-corporate dispute, it would be remanded to the RTC
just the same.
Transfarm & Co., Inc. vs. Daewoo Corporation (343 SCRA 410) July 27, 2010
Jurisdiction of SEC
Movers-Baseco Integrated Port Services, Inc. vs. Cyborg Leasing Corp.
Facts: Cyborg Leasing Corp filed before the MTC of Manila a case captioned
"Damages with prayer for a writ Replevin" against Conpac and Movers. It was
alleged that pursuant to a lease agreement, Cyborg had delivered one forklift to
Conpac. The lease agreement stipulated a monthly rental of P11,000.00 for the
use of the equipment. Conpac failed and refused to pay the stipulated rentals.
Petitioner took control of the operations of Conpac and seized all the cargoes
and equipment in ludi g the subject porklift. Petitioner ignored Cyborg's demand
for the return to it of the equipment and the formal disclaimer of ownership made
by Conpac. A Writ of Replevin was issued. Petitioner was served with a copy of
the summons and the latter filed a motion to dismiss the case on the ground of
lack of jurisdiction on the part of the of MTC since the complaint had asked
for the actual market value of the equipment, actual damage,, exemplary
damages and atty's fees. MTC dismissed the complaint for lack of jurisdiction.
Cyborg filed a petition for certiorari and prohibition with preliminary injuction
against MTC Judge, COnpac and Movers before the RTC f Manila. RTC granted
Cyborg's application for preliminary injunction. Petitioner assails the decision of
RTC. Hence this petition.
Facts: Daewoo Corp (Daewoo) entered into a joint venture agreement with
Transfarm & Co. (Transfarm) for the delivery, assembly, production & distribution
of Daewoo cars in the country. Transdaewoo Automotive Manufacturing
Company was to be incorporated with Transfarm owning 70% & Daewoo 30%.
Transfarm & TAMC were then to enter into a separate agreement that would
name Transfarm as the exclusive distributor in the country of Daewoo cars.
Parties stipulated that controversies or claims arising out of the joint venture
itself should be settled by arbitration conducted in Hong Kong but the joint
venture agreement itself was to be governed & construed in accordance with
Philippine
laws.
When the agreement went awry, Transfarm & TAMC filed a complaint with the
RTC against Daewoo & Daewoo Motor Co., Ltd. (DMCL), a corp organized
under Korean laws & not doing business in the Phils, praying that Daewoo &
DMCL be ordered to refrain from doing business here. An MTD was filed on the
ground that what was field was an intracorp controversy hence cognizable by
the SEC. RTC denied such MTD. CA dismisses the case & says that
jurisdiction is with the SEC. With a subsequent MR rebuffed, Transfarm now
files
a
petition
with
the
SC.
During the pendency of the petition with the SC, RA8799 was enacted.
- The instant case, neither filed nor pending with the SEC, let alone ready for
final resolution by it, is clearly cognizable by the RTC.
EXTRA: Statutes regulating court jurisdiction & procedure are generally
construed to be applicable to actions pending & undetermined at the time of the
passage of said enactments.
Facts: Petitioner and respondent were married, and after a bitter quarrel,
petitioner left the conjugal abode bringing with him their three sons (2 of which
are minors) to Albay and to Laguna subsequently. Respondent filed a petition for
habeas corpus in the Court of Appeals for their their 2 minor sons on the ground
that petitioners act disrupted their education and deprived them of their
mothers care.
Petitioner filed a memorandum alleging that respondent was unfit to take
custody of their children and questioned the jurisdiction of the Court of Appeals
claiming that under Section 5(b) of RA 8369, family courts have exclusive
original jurisdiction to hear and decide the petition for habeas corpus filed by
respondent.
The Court of Appeals rendered a decision asserting its authority to take
cognizance and ruling, that under the Family Code, respondent was entitled to
custody of the minors.
Petitioner challenges the jurisdiction of the Court of Appeals over the petition
for habeas corpus and insists that jurisdiction over the case is lodged in the
family courts under RA 8369.
Issue: WON the Court of Appeals has jurisdiction over habeas corpus cases
involving custody of minors.
Held: Yes. The Supreme Court ruled in a previous jurisprudence that The Court
of Appeals should has cognizance of this case since there is nothing in RA 8369
that revoked its jurisdiction to issue writs of habeas corpus involving the custody
of minors. RA 8369 did not divest the Court of Appeals and the Supreme Court
of their jurisdiction over habeas corpus cases involving the custody of minors.
The concurrent jurisdiction of the Court of Appeals and Supreme Court with
family courts in said cases was further affirmed by A.M. No. 03-03-04-SC (April
22, 2004) in Re: Rule on Custody of Minors and Writ of Habeas Corpus in
Relation to Custody of Minors which provides that:
Section 20. Petition for writ of habeas corpus. A verified petition for a writ of
habeas corpus involving custody of minors shall be filed with the Family Court.
The writ shall be enforceable within its judicial region to which the Family Court
belongs.
xxx
xxx
xxx
The petition may likewise be filed with the Supreme Court, Court of Appeals, or
with any of its members and, if so granted, the writ shall be enforceable
anywhere in the Philippines.
Held: Where the civil case is to lift levy over and annulment of the sale of the
property on the ground that it was not owned by the respondent in the labor
case, the civil court has jurisdiction. Where the action attacked the regularity of
the issuance of the writ of execution in the labor case, the labor officials have
jurisdiction. If the action does not attack the issuance, but the manner of
execution, the civil courts have jurisdiction.
s
expense. +o#ever, thepetitioner a$rupt"y resi&ned !rom the respondent
$ank $are"y a month a!ter his emp"oyment and re-oined his !ormeremp"oyer. n
June 19, 1998, the respondent $ank !i"ed a omp"aint
the same
are "ear"y
$reah
o! ontrat.
0he petitioner !
i"ed a motion to dismiss the omp"aint
!or dama&es
o! the respondent $ank #as#ithin the ex"usive
-urisdition
!or
dama&es arose out o! or #ere in onnetion
#ith hisemp"oyeremp"oyee
re"ationship #ith the respondent $ank or some aspet or inident
o! suh
!or
dama&es #as #ithin the ex"usive
-urisdition
3"thou&hits "aims
!
or dama&es inidenta""y
prediated
has -urisdition
over the same, are determined $y the materia" a""e&ations o! the omp"aint
and the re"ie!sprayed !or in re"ation to the "a# invo"ved. 7ot every ontroversy
is #ithin the
ex"usive
-urisdition
-urisdition
onnetion:
$et#een the"aim
asserted and
emp"oyeeemp"oyer re"ation. 3$sent suh
a "ink, the omp"aint
#i"" $e o∋a$"e
o! -ustie.3tions
$et#een emp"oyees and emp"oyer #here
the emp"oyeremp"oyee re"ationship is mere"y inidenta"
o!ation
preedes
-urisdition
o!
the re&u"ar ourt.
0he -urisditiono!
$ar&ainin&
a&reements. Jurisprudene
has evo"ved the ru"e that "aims !or dama&es under
para&raph 4 o! 3rti"e
215, to $e o∋a$"e
onnetion
an
the
private respondents !irst ause
o! ation
on the
petitioners emp"oyment o! deeitand
0he private
respondent #as "e!t in a "urh,
and its orporate
ontainin&
on!identia"
in!ormation on
emp"oyee ompensation
auseo!
ation,
the
petitioner simp"y #a"ked a#ay !rom his emp"oyment #ith the private respondent
sans any #ritten notie,
to thepre-udie
o! the private respondent, its $ankin&
operations and the ondut
o! ation,the
petitioner made !a"se and dero&atory statements that the private respondent
rene&ed on its o$"i&ations under theirontrat
the
private respondent as un#orthy o! trust. 0he primary re"ie! sou&ht is !or
"i=uidated dama&es !or $reah
o! a ontratua"
!"o#in& !rom
$reah
o! an o$"i&ation,intrinsia""y
a ivi"
o!
ation
o! ation
are intrinsia""yivi".
0here is no ausa"
o! ation
o!
ation
a&ainst the o so
Mangaliag v. Pastoral
Facts: Respondent Serquina filed a complaint for damages with the RTC
against petitioners Mangaliag and Solano. This complaint alleges that the
Serquina and his co-passengers sustained serious injuries and permanent
deformities from the collision of their tricycle with the petitioners dump truck and
the gross negligence, carelessness and imprudence of the petitioners in driving
the dump truck. Respondents seek damages in the form of medical expenses
amounting to P71,392.00. Respondents also claim P500,000.00 by way of moral
damages, as a further result of his hospitalization, lost income of P25,000.00 or
the nominal damages, and attorneys fees.
Petitioners filed their answer with counterclaim. After pre-trial conference, trial on
the merits ensued. After the respondent rested his case, petitioners testified in
their defense. Subsequently, petitioners filed a motion to dismiss on the ground
of lack of jurisdiction over the subject matter. They alleged that since the
principal amount prayed for, in the amount of P71,392.00, falls within the
jurisdiction of MTC. Petitioners maintain that the courts jurisdiction should be
based exclusively on the amount of actual damages, excluding therefrom the
amounts claimed as moral, exemplary, nominal damages and attorneys fee, etc.
The respondent opposed the motion saying that since the claim for damages is
the main action, the totality of the damages sought to be recovered should be
considered in determining jurisdiction. He relied on Administrative Circular No.
09-94 which provides that in cases where the claim for damages is the main
cause of action. . . the amount of such claim shall be considered in determining
the jurisdiction of the court Also, the petitioners defense of lack of jurisdiction
has already been barred by estoppel and laches. He contends that after actively
taking part in the trial proceedings and presenting a witness to seek exoneration,
it would be unfair and legally improper for petitioners to seek the dismissal of the
case.
RTC ruled in favor of respondent. Petitioners filed an MR which was denied.
Subsequently, they filed a petition for certiorari with the SC.
Issues: (1) Whether petitioners are barred from raising the defense of the RTCs
lack of jurisdiction? NO
(2) (Not really an issue raised by the respondent himself, but was nonetheless
discussed by the SC) On the issue whether a direct recourse by petition
for certiorari to the SC from the order of RTC: Generally a direct recourse to
this Court is highly improper, for it violates the established policy of strict
observance of the judicial hierarchy of courts. Although this Court, the RTCs
and the CA have concurrent jurisdiction to issue writs of certiorari, prohibition,
mandamus, quo warranto, habeas corpus and injunction, such concurrence
does not give the petitioner unrestricted freedom of choice of court forum. This
Court is a court of last resort, and must so remain if it is to satisfactorily perform
the functions assigned to it by the Constitution and immemorial tradition.
Thus, this Court, as a rule, will not entertain direct resort to it unless the redress
desired cannot be obtained in the appropriate courts, and exceptional and
compelling circumstances, such as cases of national interest and of serious
implications, justify the availment of the extraordinary remedy of writ of
certiorari, calling for the exercise of its primary jurisdiction.
Be that as it may, the judicial hierarchy of courts is not an iron-clad rule. It
generally applies to cases involving warring factual allegations. For this reason,
litigants are required to repair to the trial courts at the first instance to determine
the truth or falsity of these contending allegations on the basis of the evidence of
the parties. Cases which depend on disputed facts for decision cannot be
brought immediately before appellate courts as they are not triers of facts.
Therefore, a strict application of the rule of hierarchy of courts is not necessary
when the cases brought before the appellate courts do not involve factual but
legal questions.
In the present case, petitioners submit a pure question of law involving the
interpretation and application of paragraph 2 of Administrative Circular No. 0994. This legal question and in order to avoid further delay are compelling
enough reasons to allow petitioners invocation of this Courts jurisdiction in the
first instance.
(Maybe it is important to note that the petition for certiorari was filed from the
denial of the RTC of the petitioners motion to dismiss. There is no final
adjudication yet as to the complaint for damages.)