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The 1997 Rules of Civil Procedure Jurisdiction of the

2000 Edition Regional Trial Courts

JURISDICTION OF THE
REGIONAL TRIAL COURTS

Ito ang third level, no? And by going over their jurisdiction, you will see that it is a court of general
jurisdiction and it is actually the workforce of the whole judiciary. Yantalagang mabigat ang
trabaho nitong RTC. Their workload is terrible. Before, somebody asked me, Dean, gusto mong mag-
judge sa RTC? Inyuha na na! (Burawi nyo!) Inyo na nang trabaho na yan because there are 2 things
there when you get the job of the RTC judge: Of course, you want to excel, you want to do your job
properly and efficiently, you will die early because of the workload. Or, you end up as one who is lazy.
You end up with administrative cases for laziness, left and right. So mabuti pa, huwag ka na lang
magtrabaho diyan, kasi mabigat ang trabaho diyan.

Q: How many RTCs are there in the Philippines, from Northern Luzon to Southern Mindanao? In
your opinion?
A: You look at the opening clause of Section 13:

Section 13 (1) Creation of Regional Trial Courts There are hereby created
thirteen (13) Regional Trial Courts, one for each of the following regions: x x

So the Judiciary law has divided the country into 13 areas which is called JUDICIAL REGION .
From the 1st to the 12th, the 13th is actually in the National Capital Region (NCR), Metro Manila. Every
division is divided into branches and the number of branches keep on increasing by law.

So, to what region do we belong? We are in the 11th judicial region. So there is one RTC for the 11th
judicial region, pero bakit yun ganoon? Davao City lang, more than 10 na? Well, here is where you
will go back to your fundamentals. A court is not the same as a judge. Yan

Actually, what the law says is that, there are 13 RTCs, and every court is divided into branches. So,
kung branches siguro, malapit nang maging 1000 throughout the country. So there are 13 courts with
almost 1000 judges. Now, as a matter of fact, if you want to know exactly how many there are, you
refer to your Section 14. Actually, this has been amended many times because from 1980 up to the
present, Congress passed laws. In fact when the law took effect, according to Section 14, there are
originally 29 RTC judges commissioned for the 11th judicial region 29 originally.

Now, from what I know, based on the amendment in 1991, it was increased from 29 to 41. So there
are supposed to be 41 RTC judges for the 11th judicial region. As I said, unless from 1991 to the present
dinagdagan na naman nila.

So 41 RTC judges shall be commissioned for the 11th judicial region. There should be 6 branches
which sits thereafter for the province of Davao del Norte, which sits at Tagum, Nabunturan and
Panabo. Four branches which sit thereat for the province of Davao Oriental which sits at Mati,
Bagangga and Butuan. Sixteen branches which sit thereat for the province of Davao del Sur. And the
City of Davao which sits at Davao City, Digos, Malita and Bansalan. Then 10 branches which sit
thereat for the province of South Cotabato and the City of General Santos which sit at General Santos
City, Koronadal [the City of Eumir, Francis and Mortz], Surallah, and Polomolok. And 5 branches
which sit thereat for the province of Surigao del Sur which sit at Tandag, Ginanga, Bislig and Kantilan.
So that is how they are distributed within the 11th the juridical region.

Q: So, since there are 41 of them scattered throughout the 11th judicial region, from Surigao to
South Cotabato, for example, I would like to file a case against my neighbor based in Davao. So i-file ko
sa Polomolok, anyway thats the same court, eh. Or a criminal in Davao City file-an sa Mati. Anyway,
the same court na. Are you allowed to do that?
A. The answer is NO! Every branch of the RTC has its own area of responsibility. Except in Davao
City, or in chartered cities, the authority of every branch here is throughout Davao City. But sa
probinsya, hati-hati yan eh, and the provision there is Section 18 of BP 129.

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2000 Edition Regional Trial Courts

BP 129, Section 18 . Authority to define territory appurtenant to each


branch The Supreme Court shall define the territory over which a branch of the
Regional Trial Court shall exercise its authority. The territory thus defined
shall be deemed to be the territorial area of the branch concerned for purposes
of determining the venue of all suits, proceedings or actions, whether civil or
criminal, as well as determining the Metropolitan Trial Courts, Municipal Trial
Courts, and Municipal Circuit Trial Courts over which the said branch may
exercise appellate jurisdiction. The power herein granted shall be exercised
with a view to making the courts readily accessible to the people of the
different parts of the region and making the attendants of litigants and witness
as inexpensive as possible.

Yan, so in the province every branch has its own defined area. So, for example if you are from
Nabunturan, you cannot file a case in Panabo. Kalayo-layo niyan. There is a branch there in
Nabunturan. Doon ka mag-file. Kanya-kanya ng responsibility.

Now, the law says, the SC has the power to define the area of its branch for purposes of supervising
that area and the MTC there. Now, as early as 1983, the SC has already come out with administrative
order throughout the Philippines defining the area of responsibility of each branch. Sometimes I need
that, eh, because there are cases to be filed outside Davao City, especially Cotabato Province. And you
have to be updated kung sang branch ba ako pupunta nito. Sometimes you have a hard time, eh. For
example, the case originated in Babak, part of Davao del Norte, saan ba ito i-file? Panabo or Tagum? I
need to consult that circular. Yanthat will be very helpful. Now you please correlate Section 18 of
the Judiciary Law with the Interim Rules Section 2 because Section 2 of the Interim Rules is related to
this, eh.

Interim Rules, Sec. 2. Territorial Jurisdiction of Courts. -


a) MetTCs, MTCs and MCTCs shall exercise their jurisdiction in the city,
municipality or circuit for which the judge thereof is appointed or designated.
b) A Regional Trial Court shall exercise its jurisdiction within the area
defined by the SC as the territory over which the particular branch concerned
shall exercise its authority, in accordance with Sec. 18 of BP 129.

Yaan! So every RTC shall have authority. Alright, these are what you call administrative
provisions.

Now, lets go to the jurisdiction of the RTC:

EXCLUSIVE ORIGINAL JURISDICTION Section 19 as amended by RA 7691


CONCURRENT ORIGINAL JURISDICTION with other courts Section 21
APPELLATE JURISDICTION Section 22

EXCLUSIVE ORIGINAL JURISDICTION OF THE RTC

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 litigation is incapable
of pecuniary estimation.

What does it mean? When the subject of the litigation is not expressed in terms of pesos, centavos.
Alright.

In most cases that we know, the demand of the plaintiff is expressed in terms of amount, eh.
EXAMPLE: A creditor will file a case for the collection of the unpaid loan from the defendant. Ang
nakalagay sa demanda niya, that after trial that the court should order the defendant to pay him the
sum of P500,000 na utang with interest. So, the subject is expressed in terms of amount of damages ba,
the court shall award to the defendant damages amounting to half a million. Karamihan ng kaso
ganyan.

But here, in this civil case, the subject of the civil case is not capable of pecuniary estimation. It
cannot be estimated or calculated in pesos.

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EXAMPLE is an action for annulment; rescission of contract; an action for specific performance; an
action for declaratory relief by express provision of the law now; an action for the permanent injunction
against somebody;

[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 P20,000 or for civil actions in Metro Manila, where such value
exceeds P50,000 except actions for forcible entry into and unlawful detainer of
lands and buildings; original jurisdiction over which is conferred upon the
Metropolitan Trial Courts, Municipal Circuit Trial Courts;

So real actions outside of forcible entry and unlawful detainer. The best example would be accion
publiciana, accion reinvidicatoria, quieting of title, provided the value of the property exceeds
P20,000.00 based on the assessed value of the property.

So, for a lesser value, MTC has jurisdiction. This is why MTCs now has jurisdiction over accion
publiciana when the value of the property is P20,000 or less. But kung forcible entry and unlawful
detainer, klaro yan walang RTC.

Now, if in Metro Manila, then value is P50,000. But outside Metro Manila, the assessed value is only
P20,000.

[3] In all civil actions in admiralty and maritime jurisdiction where the
demand or claim exceeds One Hundred Thousand pesos (P100,00.00) [now PhP
200,000.00] or, in Metro Manila, where such demand or claim exceeds Two Hundred
Thousand pesos (P200,000.00)[now, PhP 400,000].

EXAMPLE: The shipper will ship to you in Davao goods involving common carrier. While in
transit, the goods are lost or they are totally damaged. You would like to file a claim or a case against
the carrier, what kind of a case? That is an admiralty or maritime case.

Q: If you are going to file a case against the shipping company, where will you file it? RTC or
MTC?
A: It depends on how much is your claim. If your claim of the damaged or lost cargo exceeds
P200,000, sa RTC; if it is P200,000 or less, sa MTC. In Metro Manila, the jurisdiction is higher it should
be over P400,000. Now do not confuse this with No. 2 because that involves LAND with more than
P20,000 value.

Take note that prior to August 16, 1999, the claim should exceed P100,000 or P200,000 in Metro
Manila as the case may be. Now, the claim is adjusted to P200,000 and P400,000, respectively pursuant
to Section 5 of RA 7691 which took effect last August 15, 1995:

RA 7691, Sec. 5. After five (5) years from the effectivity of this Act, the
jurisdictional amounts mentioned in Sec. 19(3), (4), and (8); and Sec. 33(1) of
Batas Pambansa Blg. 129 as amended by this Act, shall be adjusted to Two hundred
thousand pesos (P200,000.00). Five (5) years thereafter, such jurisdictional
amounts shall be adjusted further to Three hundred thousand pesos (P300,000.00):
Provided, however, That in the case of Metro Manila, the abovementioned
jurisdictional amounts shall be adjusted after five (5) years from the
effectivity of this Act to Four hundred thousand pesos (P400,000,00).

So after August 16, 1999 (5 years from the effectivity of RA 7691) yung P100,000.00 naging P200,000
na. Yung P200,000 in Metro Manila, naging P400,000. Then after another 5 years (2004), aakyat na
naman ang jurisdiction ng MTC. So from the original P100,000.00 magiging P300,000 na yan. Automatic
ha.

[4] In all matters of probate, both estate and intestate, where the gross
value of the estate exceeds One Hundred Thousand pesos (P100,000.00) [now
P200,000] or, in probate matters in Metro Manila, where such gross value exceeds
Two Hundred Thousand pesos (P200,000.00) [now P400,000].

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In the subject of Wills and Succession, when a person dies, his estate, his property will be settled for
the benefit of his creditors and heirs. That is what you call either as testate or intestate proceedings
depending on whether the deceased left a will or none.
Q: Where should the estate of the deceased person be settled, RTC or MTC?
A: It depends on how much is the gross value of his estate. If it exceeds P200,000, RTC. If it is
P200,000 or less, it should be with the MTC. In Metro Manila again, it is doubled, the gross should be
more than P400,000. And again, this will automatically increase after 5 years from 1999.

[5] In all actions involving the contract of marriage and marital relations.

Most of these cases are under the Family Code.

Q: What are the possible actions which you can imagine involve the contract of marriage and
marital relations?
A: Annulment of marriage, legal separation, declaration of nullity, dissolution of the absolute
community of husband and wife, and action for support. These cases are the ones arising under the
Family Code, where it arises out of a marital relationship.

Take note that these cases are NO LONGER covered by the RTC because under RA 8369 (Family
Courts Act of 1997), these cases should now be tried by the FAMILY COURTS.

RA 8369, SECTION 5. Jurisdiction of Family Courts. The Family Courts shall


have exclusive original jurisdiction to hear and decide the following cases:
x x x x x x
d) Complaints for annulment of marriage, declaration of nullity of marriage
and those relating to marital status and property relations of husband and wife
or those living together under different status and agreements, and petitions
for dissolution of conjugal partnership of gains;
x x x x x x

Now, in areas where there are no family courts, the cases shall be adjudicated by the RTC. So
certain branches of the RTC will act as family courts (acting family courts).

We shall skip first no. 6. We will return to that later. Lets go to no. 7.

[7] In all civil actions and special proceedings falling within the
exclusive original jurisdiction of a Juvenile and Domestic Relations Court and
of the Court of Agrarian Relations as now provided by law;

Before BP 129, these were special courts existing before 1980. Among these courts were the so
called Juvenile and Domestic Relations Courts (JDRC). Then you have the Court of Agrarian Relations
(CAR) which tried the cases involving tenancy, agricultural lessor, agricultural lessee, agricultural
lands. When BP 129 was enacted, the CAR and the JDRCs were abolished. Cases which they used to
handle were automatically transferred to the RTC. That was after BP 129 took effect.

What were the cases which were usually falling within the original jurisdiction of the former JDRC?
Usually, those involving family and children, like support filed by the child against his father,
compulsory recognition, custody of children, adoption proceedings these are the cases which are
usually heard by the JDRC.

Under BP 129, all of these are now within the jurisdiction of RTC. HOWEVER, this has been
amended again by RA 8369 (Family Courts Act of 1997) These cases are now under the jurisdiction of
the FAMILY COURTS: (See Sections 5 [b], [c], [e], [g])

RA 8369, SECTION 5. Jurisdiction of Family Courts. The Family Courts shall


have exclusive original jurisdiction to hear and decide the following cases:
x x x x
b) Petitions for guardianship, custody of children, habeas corpus in
relation to the latter;
c) Petitions for adoption of children and the revocation thereof;
x x x x

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g) Petitions for declaration of status of children as abandoned, dependent


or neglected children, petitions for voluntary or involuntary commitment of
children; the suspension, termination, or restoration of parental authority and
other cases cognizable under Presidential Decree No. 603, Executive Order No.
56, (Series of 1986), and other related laws;
x x x x x

But the law transferring the jurisdiction of the CAR to the RTC became partially obsolete with the
enactment of the Comprehensive Agrarian Reform Law (CARL) or RA 6657 (June 15, 1988). Under the
CARL, all agrarian disputes between landlord and tenant, lessor and lessee were transferred to the
DAR particularly the DAR Adjudication Board (DARAB), making them quasi-judicial cases . So, from
CAR to RTC, from RTC to DARAB

So the RTC has NO jurisdiction, EXCEPT in the following 2 cases:

1.) Cases where the issue is PAYMENT OF JUST COMPENSATION, f or, the property which has
been taken under CARP law;

EXAMPLE: If you are a landowner and your agricultural land is placed under the CARP
coverage, the government will fix the payment for you. The trouble is that you did not lot
agree on the amount of payment. Agrabiyado ka sa compensation ng gobyerno. Now, you
go to RTC and you ask for higher compensation.

1.) Prosecution of criminal offenses for violation of the CARL;

So these are the only agrarian cases which still belongs to the RTC. This was explained by the SC in
the case of

QUISMUNDO vs. COURT OF APPEALS


201 SCRA 609 [1991]

HELD: Wth the enactment of Executive Order No. 229, which took effect on August
29, 1987, the Regional Trial Courts were divested of their general jurisdiction to try
agrarian reform matters. The said jurisdiction is now vested in the Department of
Agrarian Reform. Said provisions thus delimit the jurisdiction of the regional trial courts
in agrarian cases only to two instances:
1.) petitions for the determination of just compensation to landowners; and
2.) prosecution of criminal offenses under said Act.

[8] In all cases in which the demand, exclusive of interest, damages of


whatever kind, attorneys fees, litigation expenses, and costs or the value of
the property in controversy exceeds One Hundred Thousand pesos (P100,000.00)
[now P200,000] or, in such other cases in Metro Manila, where the demand,
exclusive of the above-mentioned items exceeds Two Hundred Thousand pesos
(P200,000.00)[now P400,000]

The best example is money claim. Most cases which go to court now are money claims an action
to collect sum of money.

Q: Unpaid loan you would like to collect an unpaid loan of your debtor. Where will you file your
case?
A: It depends on how much are you collecting. If it is over P200,000 outside Metro Manila RTC,
in Metro Manila, double the amount P400,000. If the amount that you are collecting is only P200,000
or less obviously, you file your case in the MTC.

If the value of the claim is > P200,000 RTC


If the value of the claim is = or < P200,000 MTC

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So this is the same as number [3] and [4] where the jurisdiction of the MTC was raised from P20,000
to P100,000. And under the present law, it is now P200,000. But again, this is subject to the automatic
increase in jurisdiction by 2004.

Q: Suppose the principal amount that you borrowed from me is P200,000, the interest is P30,000.
And you are collecting P10,000 for moral damages, another P10,000 for expense of litigation, etc. So my
total claim is P250,000. Where will I file the case?
A: MTC pa rin. In determining the jurisdictional limit of P200,000, do not include the interest,
damages, attorneys fees, etc. So you deduct those from the principal claim even if you put them in
your complaint because the law says, xxx exclusive of interest, damages of whatever kind, attorneys
fees, litigation expenses, and costs xxx.

Q: What are litigation expenses and costs?


A: Costs are not the same as attorneys fees and litigation expenses. Actually, attorneys fees and
litigation expenses are part of damages. Costs are governed by Rule 141, while attorneys fees and
litigation expenses are governed by the Civil Code. Because there is some confusion there, akala ang
costs and litigation expense, pareho. No, they are not the same.

ACTIONS PURELY FOR DAMAGES

SITUATION: Suppose the action is purely for damages, like breach of contract of carriage. Instead
of bringing you to your destination, you ended up in the hospital. You now sue the common carrier for
damages and your claim is P1 million for injuries, moral, exemplary, etc. Now, because the law says the
jurisdiction of the RTC is above P200,000 but do not include damages. The claim in this case is P1
million, all for damages. Now, where will you file the case?

Somebody said it should be in the MTC because in determining the jurisdiction of the RTC, you do
not include damages. If that is the interpretation, I said, all damage suits cannot be tried by the RTC
because remember, you pay filing fee for these cases but the jurisdiction is limited to the MTC. That is
absurd! I do not believe that kung puro damages wala ng jurisdiction ang RTC. Otherwise, all damage
suits should be filed in the MTC.

This question has been clarified by SC Circular No. 09-94: Guidelines in the Implementation of RA
7691 Extending the Jurisdiction of the MTCs where the SC said that the provision excluding damages
applies only if the damages are INCIDENTAL to the action. If the main cause of action is 100%
damages, you include it in determining the P200,000 jurisdictional limit of the MTC.

EXAMPLE: Ms. Pastor rode on a PAL fight. The plane crashed but she survived. She claims for
damages for breach of contract of carriage amounting to P1 million.
Q: Where will she file her case?
A: RTC because the amount of the claim for damages exceeded P200,000. Since the case is purely for
damages, it is included in determining the jurisdiction of the court.

The rule is, you only exclude the damages if it is a secondary claim. But if damages is the primary
or only claim, you determine whether the total claim for damages is above P200,000, or equal to or less
than P200,000. Yaaann!

The SC said in this Circular, the exclusive damages of whatever kind in determining the
jurisdiction under Section 19 paragraph [8] applies to cases where the damages are merely incidental to
or a consequence of the main cause of action. However, if the claim for damages is the main cause of
action, the amount of such claim should be considered in determining the jurisdiction.

EXAMPLE: Inay will file a case against Janis to recover a piece of land worth P20,000.00 only. But
her claim for damages exceeds P300,000. So, you will notice ang claim for damages is incidental lang.
Ang main action is to recover a piece of land.
Q: In what court will Inay file a civil case where she wants to recover a piece of land with value of
only P20,000?

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A: MTC because of paragraph [2]. But ang damages naman is P300,000? MTC pa rin iyan because
such damages, being incidental, is not included in determining the jurisdiction of the RTC.

However, if my actions against you is purely damages, like I will file a case against you for
damages arising from vehicular collision and I will claim P300,000 for damages, it should be in the
RTC. That is the explanation. The term excluding damages applies only if the damages are purely
incidental to the case. But if the action is purely damages, then you observe the P200,000 jurisdictional
limit.

Now, the law says, exclusive of interest, damages of whatever kind, attorneys fees, litigation
expenses, and costs or THE VALUE OF THE PROPERTY IN CONTROVERSY exceeds P200,000.

Q: What is the property in controversy?


A: Obviously here, the property is PERSONAL PROPERTY not real. If the property sought to be
recovered is real, apply paragraph [2] of Section 19 on recovery of real property.

Q: In the subject of Sales, the unpaid seller would like to rescind the sale and get back the unit.
Where will the unpaid seller file the case?
A: If above P200,000 sa RTC ka. It if is only P200,000 or less, sa MTC. So this is an example of the
value of the [personal] property in controversy.

Q: (By a classmate, Review class) Who shall determine the value or how should the value be
determined?
A: You will learn the answer when we reach Rule 16 on Motion to Dismiss. In determining the
jurisdiction of the court, in the meantime, which will prevail? You will learn later that the allegations of
the complaint will prevail.

Like for example, I will file a case against you for an unpaid loan of P250,000. Then you say in your
motion to dismiss, No! ang utang ko sa iyo is not P150,000, but only P80,000. Therefore, the RTC has
no jurisdiction. So there is now a conflict with what Im saying and with what you are saying.

With that, we will discuss the conflict later. Now, we do not know who is telling the truth. For the
moment, the rule is, you follow the plaintiff because jurisdiction is determined by the allegations of the
complaint. It is the complaint which will determined whether the court has jurisdiction over the subject
matter. It is not based on what the defendant is saying. That is the answer there.

Let us go to some interesting cases on this provision.

ORTIGAS AND CO., LTD PARTNERSHIP vs. HERRERA


120 SCRA 89 [1983]

FACTS: A entered into an agreement with B where A deposited the sum of P50,000 with
B. After certain conditions are complied B has to return the amount to A. According to A the
conditions are already complied with but B still refuses to return the money. So A filed a
complaint which he denominated as sum of money and since he is only asking for the
return of P50,000, A filed the case in the MTC.

ISSUE #1: Whether or note the MTC has jurisdiction over the case.
HELD: The MTC has NO jurisdiction. It should be filed in the RTC. It is not an action to
collect a loan. You are not recovering a loan. You are compelling him to comply with the
agreement to return the money after certain condition are complied with, di ba? You are
trying to enforce your agreement. therefore your action is an action for SPECIFIC
PERFORMANCE which should be tried by the RTC under paragraph [1].
When a party to a contract has agreed to refund to the other party a sum of money
upon compliance by the latter of certain conditions and only upon compliance therewith
may what is legally due him under the written contract be demanded, the action is one not
capable of pecuniary estimation. So it is cognizable by the RTC.
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ISSUE #2: But according to the plaintiff, when he filed the complaint, it is entitled for
sum of money which should fall under paragraph [8]. Is the plaintiff correct?
HELD: NO. The plaintiff is wrong. The title of the action is not determinative of the
court. Just like the rule on contracts where the nature of the contract is not determined by
the title but by stipulation.
The factual allegations in the complaint seeking for the performance of an obligation of
a written contract which is a matter clearly incapable of pecuniary estimation prevail over
the designation of the complaint as one for the sum of money and damages.

[6] In all cases not within the exclusive jurisdiction of any court,
tribunal, person or body exercising judicial or quasi-judicial functions

Practically, this makes the RTC the universal catcher what does not belong to anyone of you,
belongs to me. Thats what this provision is saying.

EXAMPLE: An employee, Inday Locsin, files a case against the employer, Kenneth Lim, to claim
non-payment of wages, overtime pay, ECOLA and reinstatement for illegal termination. Under the
Labor Code, dapat sa NLRC. So it does not belong to RTC but if there is no vesting to NLRC, then it
goes to the RTC.

A case which does not belong to any other court. Lets try to connect it with something you know.

Q: If you want to file an action for annulment of judgment of RTC, where will you file your action?
A: CA only an exclusive original jurisdiction of the action for annulment of the judgment of the
RTC.

Q: Suppose Karen will file an action for annulment of judgment of the MTC. Does it belong to the
CA?
A: NO! What the law says is: annulment of judgment of RTC, and not MTC. How about Supreme
Court? Lalong wala. Saan ka pupunta? There is really no provision in BP 129 which goes that way. I
dont think you can go to NLRC.

Wala kang mapuntahan, saan ka tatakbo? Sa RTC because it does not belong to the jurisdiction of
any other court. It should fall under paragraph [6] That is why, this, there are problems reaching the
SC on jurisdiction whether a case belongs to this, to the regular court or to a special quasi-judicial
body. And we are going to go over some of these cases.

SANDOVAL vs. CANEBA


190 SCRA 77 [1990]

FACTS: The quarrel in this case involves the owner of the subdivision and the buyer.
Later on, the buyer refused to pay the unpaid installments. The subdivision developer filed
a case for the collection of unpaid installments over the subdivision lots. Now, if you look at
the law, parang money claims sa RTC or MTC.

HELD: The regular courts have no jurisdiction. That should be decided by the Housing
and Land Use Regulatory Board (HLURB) formerly known as NHA. Under PD 957, it is the
HLURB not the RTC or MTC which has the jurisdiction to hear a case involving non-
payment of installments over subdivision lots.

The counterpart of this case was the case of

CT TORRES ENTERPRISES, INC. vs. HIBIONADA


191 SCRA 268 [1990]

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FACTS: This is also the case between the buyers of a subdivision lot against the
subdivision developer. Only this time baliktad it is the subdivision lot buyers who are
suing the developer of the subdivision. The subdivision lot owners filed against the
subdivision developer for not maintaining properly the roads of the subdivision. So they
filed a case for specific performance with damages to compel the developer to comply with
the contract to maintain the roads.

HELD: The jurisdiction is with the HLURB and not with the regular courts. But
according to the plaintiff But Im also claiming for damages so that it should be filed before the
regular courts. How can the HLURB award damages? Only the regular courts can award the
damages. Can the HLURB award damages? According to the SC:
The argument that only courts of justice can adjudicate claims resoluble under the
provisions of the Civil Code is out of step with the fast-changing times. There are hundreds
of administrative bodies now performing this function by virtue of a valid authorization
from the legislature. This quasi-judicial function, as it is called, is exercised by them as an
incident of the principal power entrusted to them of regulating certain activities falling
under their particular expertise.
So quasi-judicial bodies are now authorized to award damages.

As a matter of fact in Labor Relations, the question is asked whether the NLRC is authorized to
grant damages also to an employee, moral and exemplary, which normally is only awarded by courts.
The Labor Code says yes. In other words, even damages now can be awarded by administrative bodies
such as NLRC.

FAJARDO vs. BAUTISTA


232 SCRA 291 [1994]

FACTS: Isabelo and Marita Jareno and the owners and developers of a subdivision.
Fajardo and others, as buyers, signed separate contracts each designated a contract to sell
under which for consideration therein stated, the Jarenos bound themselves to sell to
Fajardo et al the of subject thereof, and after the latter shall have paid the purchase price and
interest shall execute in favor of Fajardo et al the corresponding deeds of sale.
When these contracts to sell are still ongoing the Jarenos sold these lots to other buyers
and the title was transferred to the second buyer. So when Fajardo et al learned about it,
they filed separate complaints with the RTC for annulment of the sale to the other buyers.
Now, according to Fajardo, the jurisdiction of the case belongs to the RTC and not with
the HLURB because the title of the lots are transferred to the other buyers. It is no longer
under the name of Jareno. Secondly, their action is for the annulment of title to a third
person. Thirdly, these third persons are not the developers; fourthly, under the Judiciary
Law, actions involving title to a real property are to be tried by the RTC.

HELD: The RTC still has NO jurisdiction because the case involved unsound real estate
business practice on the part of the subdivision owners and developers. Under the law,
unsound real estate business practice is under the HLURB. The practice in the case is not a
sound real estate business I am a developer, I enter into a contract with you and then later
on I sold the contract to a third person, that is unsound!
By virtue of P.D. 1344, the HLURB has the exclusive jurisdiction to hear and decide the
matter. In addition to involving unsound real estate business practices, the complaints also
involve specific performance of the contractual and statutory obligations of the owners or
developers of the subdivision. So it is still with the HLURB and not with the regular courts.

BENGUET CORPORATION vs. LEVISTE


204 SCRA 99 [1991]

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FACTS: A mining company entered into a operations agreement for management with
another mining company. Then later on, one wants to file a case for rescission of the
agreement for one reason or another. So it was filed with the RTC.

HELD: The RTC has NO jurisdiction again because PD 1281 vested with the Bureau of
Mines with jurisdictional supervision and control over all issues on mining claims and that
the Bureau of Mines shall have the original exclusive jurisdiction to hear and decide cases
involving the cancellation and enforcement of mining contracts.

The trend is to make the adjudication of mining cases a purely administrative matter. Another case
is the case of

MACHETE vs. COURT OF APPEALS


250 SCRA 176 [1995]

FACTS: This case involves the collection by the landowner of unpaid back rentals from
his leasehold tenants. The landowner filed the money claims before the RTC.

HELD: The RTC has no jurisdiction over cases for collection of back rentals for the
leasehold tenants. This is an agrarian dispute which exclusively cognizable by the DARAB.
The failure of petitioners to pay back rentals pursuant to the leasehold contract with
landowner is an issue which is clearly beyond the legal competence of the trial court to
resolve. The doctrine of primary jurisdiction does not warrant a court to arrogate unto itself
the authority to resolve a controversy the jurisdiction over which is initially lodged with an
administrative body of special competence.

Lets go to Professional Regulation Commission (PRC). That is the government body which
administers all government examination for professionals except members of the law profession. Sa
medicine, CPA, engineer, lahat andiyan sa kanila, including plumber and marine officers. Basta lahat
ng merong examination sa kanila yan except sa bar which is under the jurisdiction of the SC. Now, this
is what happened in the case of

LUPANGCO ET AL vs. COURT OF APPEALS


160 SCRA 848 [1988]

FACTS: Lupangco et al were BS Accounting graduates and reviewing to take the CPA
exams in 1985.
There were some anomalies (leakages) in the 1985 CPA Board Examination. By next
year, the PRC passed a resolution prohibiting CPA examinees to attend review classes or
conferences because of leakages. They are prohibited from receiving any handouts, review
materials or any tip from any school, college or university. That was Resolution No. 105 of
the PRC.
So petitioners Lupangco et al, all CPA reviewers filed an injunction suit against the PRC
and to declare the resolution unconstitutional. They filed it with the RTC. The PRC moved
to dismiss alleging that the RTC has no jurisdiction over the case because the one which has
the jurisdiction is the CA exclusive jurisdiction to review any decision, order, ruling or-
resolution of any quasi-judicial body. And the PRC is a quasi-judicial body. So their
resolution can only be questioned before the CA and not with the RTC.

HELD: The PRC is WRONG because PRC is not only a quasi-judicial body, it is also a
quasi-legislative body. It also acts as legislative body by issuing rules and regulations.
Now, what kind of resolution is being questioned here? It is a resolution pursuant to it
purely administrative function. It is a measure to preserve the integrity of licensure
examination. Therefore, it does not belong to the CA. It is not the type of resolution
contemplated by Section 9.
The authority of the CA to review all resolutions of all quasi-judicial bodies pursuant to
the law does not cover rules and regulations of general applicability issued by the
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administrative body to implement its purely administrative policies and functions like
Resolution No. 105 which was adopted by the PRC as a measure to preserve the integrity of
licensure examinations. So that is not the resolution reviewable by the CA.
Now, under what provision under Section 19 can we justify the jurisdiction of the RTC
in the case. The SC said: It is under paragraph 1 where the case is incapable of pecuniary
estimation or, it may fall under paragraph 6 where the case is not within the exclusive
jurisdiction by any court, tribunal or- body exercising Judicial or quasi-judicial functions.

So, if it is not reviewable by the CA, in what court can you question the resolution? Definitely, not
the CA, definitely not the SC. I dont think its with the NLRC. So it will fall under the jurisdiction of
the RTC. Or, it can also fall under paragraph [1,] where the subject matter of the suit is not capable of
pecuniary estimation because what is the nature of the demands is to declare unconstitutional this
resolution. So it belongs to the jurisdiction of the RTC.

BERNARDO vs. CALTEX PHIL. INC.


216 SCRA 170 [1992]

FACTS: Under E.O. No. 172, when there is a dispute between an operator or dealer and
an Oil company regarding dealership agreement, the case shall be under the jurisdiction of
the Energy Regulatory Board (ERB). So any dispute regarding their relationship agreement
except disputes arising out of the relationship as debtor and creditor. So if the dispute arose
out of the relationship as bebtor and creditor, it should be filed with the RTC.
Now what happened here is that on December 5, 1990, Bernardo, a dealer of Caltex,
ordered gasoline from Caltex. So he ordered in the morning. At 6:00 at night on the same
day, there was a price increase. So when the gasoline was delivered the following day,
Caltex charged Bernardo for the increased price. Bernardo refused to pay and he he filed a
case before the RTC. Caltex argued that the case should be filed with the ERB.

HELD: The RTC has jurisdiction because a contract of sale of petroleum products was
here perfected between Caltex and its operator/dealer Bernardo; that in virtue of the
payment admittedly made by Bernardo, Caltex became a debtor to him in the sense that it
was obligated to make delivery to Bernardo of the petroleum products ordered by him; and
that the only issue is the manner by which Caltex shall perform its commitment in
Bernardos favor. It is rather one cognizable by the Regional Trial Court, as a dispute indeed
arising out of their relationship as debtor and creditor.
What the controversy is all about, to repeat, is simply the prices at which the petroleum
products shall be deemed to have been purchased from Caltex by Bernardo in December 5,
1990. This is obviously a civil law question, one determinable according to the provisions of
the Civil Code and hence, beyond the cognizance of the Energy Regulatory Board.

CONCURRENT ORIGINAL JURISDICTION OF THE RTC

Sec. 21. Original jurisdiction in other cases. - Regional Trial Courts shall
exercise original jurisdiction:

[1] In the issuance of writs of certiorari, prohibition, mandamus, quo


warranto, habeas corpus, and injunction which may be enforced in any part of
their respective regions;

Q: What is the difference between the original jurisdiction of the RTC in Section 21 and the original
jurisdiction of the RTC in Section 19?
A: In Section 19, you have the EXCLUSIVE original jurisdiction, whereas in Section 21 you have the
original jurisdiction but CONCURRENT with other courts.

Thus original jurisdiction stated in Section 21 is also shared with the SC and CA. Therefore , the
SC, CA, and RTC have original concurrent jurisdiction under Section 21. Like issuance of writs of
certiorari, prohibition, mandamus, quo warranto, habeas corpus, etc. This is concurrent with the CA
and the SC. Such writs may be issued by (a) the RTC under Section 19; (b) CA under Section 9; and (c)
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SC under Article VIII Section 5 of the Constitution. The 3 courts share concurrent jurisdiction over these
cases.

However the only difference is that writs issued by an RTC can only be enforced in the same region
where the RTC belongs. Unlike writs issued by the SC and CA, they can be enforced anywhere in the
Philippines.

[2] In actions affecting ambassadors and other public ministers and consuls.

The SC and RTC have original concurrent jurisdiction in actions affecting ambassadors, other
public ministers and consuls. Section 21 paragraph 2 states only of the concurrent original jurisdiction
of the SC and RTC. Section 19 on the jurisdiction of CA does not include the action stated in section 21
paragraph 2 as part of its (CAs) jurisdiction.

APPELLATE JURISDICTION OF THE RTC

Sec. 22. Appellate jurisdiction. - Regional Trial Courts shall exercise


appellate jurisdiction over all cases decided by MetTCs, MTCs and MCTCs in their
respective territorial jurisdictions. Such cases shall be decided on the basis
of the entire record of the proceedings had in the court of origin and such
memoranda and/or briefs as may be submitted by the parties or required by the
RTCs. The decision of the RTCs in such cases shall be appealable by petition
for review to the CA which may give it due course only when the petition show
prima facie that the lower court has committed an error of fact or law that will
warrant a reversal or modification of the decision or judgment sought to be
reviewed.

Now take note that the RTC also has appellate jurisdiction under Section 22. These are cases
decided by the MTC. So they act as a sort of court of appeals. The RTC exercises appellate jurisdiction
over all cases decided by the MTC in their respective territorial jurisdiction.

Q: How will the RTC decide on the appeal?


A: It shall be decided on the basis of the entire record of the proceedings had in the court of origin
(MTC) such as memoranda and/or briefs as may be submitted. This means that witnesses will not be
made to appear again in the appeal. It is only a matter of reviewing the testimony, stenographic notes,
evidence presented, memoranda and briefs by the RTC judge.

Q: What are memoranda and briefs?


A: It is where the appealing party will argue that the decision is wrong and try to convince the
judge that the decision is wrong, and the other party to counter act that the decision is correct.

Q: Assuming that the case is originated in the MTC and subsequently dismissed by the RTC on
appeal, is the decision by the RTC rendered pursuant to its appellate jurisdiction appealable to the CA?
A: YES, but the mode of appeal is now different. The decision of the RTC in such cases shall be
appealable by petition to review to the CA. The CA may or may not give it due course.

Q: What is the difference between an appeal made from the RTC to CA and appeal from the MTC
to RTC, which is dismissed the same and subsequently appealed to the CA?
A: The former (RTC CA) is in pursuance to the original jurisdiction of the RTC. The latter (MTC-
RTC-CA) is in pursuance to the appellate jurisdiction of the RTC. (They are governed by different
rules)

To illustrate:

Pursuant to original jurisdiction of the RTC: Pursuant to appellate jurisdiction of the RTC:

COURT OF APPEALS COURT OF APPEALS

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Ordinary appeal Petition for Review


(Rule 41) (Rule 42)

RTC RTC

Ordinary Appeal
(Rule 40)

MTC

Unlike in a case under the original jurisdiction of the RTC, where an appeal to the CA is a matter of
course. Meaning, for as long as your appeal is on time and properly made, the CA will entertain it.

It is different, however, in a case under the appellate jurisdiction of the RTC, even if your appeal is
on time and properly made, there is no assurance that the CA will entertain the appeal. The CA may
give it due course only when your petition for review shows prima facie evidence that the lower court
has committed as error of fact or law that will warrant a reversal or modification of the decision or
judgment sought to be reviewed.

Now, statistically for the past 20 years, the rate of petitions for review from the RTC which are
given due course is only 15%-17%. For every 100 petitions for review, 15 are given due course, 85 are
thrown out. They did not pass the test under Section 22. It is really a difficult process.

Summary of RTC jurisdiction:


1.) As to the EXCLUSIVE original jurisdiction Section 19 (BP 129);
2.) As to its original CONCURRENT jurisdiction Section 21 (BP 129);
3.) As to its APPELLATE jurisdiction Section 22 (BP 129)

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