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BARANGAY SAN ROQUE, TALISAY, CEBU vs.

Heirs of where the subject of the litigation may not be estimated in


FRANCISCO PASTOR (G.R. No. 138896. June 20, 2000) terms of money, and are cognizable exclusively by courts of
first instance. The rationale of the rule is plainly that the
second class cases, besides the determination of damages,
demand an inquiry into other factors which the law has
FACTS: Petitioner filed before the Municipal Trial Court deemed to be more within the competence of courts of first
(MTC) of Talisay, Cebu (Branch 1) a Complaint to instance, which were the lowest courts of record at the time
expropriate a property of the respondents. In an Order dated that the first organic laws of the Judiciary were enacted
April 8, 1997, the MTC dismissed the Complaint on the allocating jurisdiction (Act 136 of the Philippine Commission
ground of lack of jurisdiction. It reasoned that "[e]minent of June 11, 1901)."
domain is an exercise of the power to take private property
for public use after payment of just compensation. In an In National Power Corporation v. Jocson, the Court ruled that
action for eminent domain, therefore, the principal cause of expropriation proceedings have two phases: "'The first is
action is the exercise of such power or right. The fact that the concerned with the determination of the authority of the
action also involves real property is merely incidental. An plaintiff to exercise the power of eminent domain and the
action for eminent domain is therefore within the exclusive propriety of its exercise in the context of the facts involved in
original jurisdiction of the Regional Trial Court and not with the suit. It ends with an order, if not of dismissal of the action,
this Court." 'of condemnation declaring that the plaintiff has a lawful right
to take the property sought to be condemned, for the public
The RTC also dismissed the Complaint when filed before it, use or purpose described in the complaint, upon the
holding that an action for eminent domain affected title to real payment of just compensation to be determined as of the
property; hence, the value of the property to be expropriated date of the filing of the complaint.' An order of dismissal, if
would determine whether the case should be filed before the this be ordained, would be a final one, of course, since it
MTC or the RTC. Concluding that the action should have finally disposes of the action and leaves nothing more to be
been filed before the MTC since the value of the subject done by the Court on the merits. The second phase of the
property was less than P20,000 "The instant action is for eminent domain action is concerned with the determination
eminent domain. It appears from the current Tax declaration by the court of 'the just compensation for the property sought
of the land involved that its assessed value is only One to be taken.' This is done by the Court with the assistance of
Thousand Seven Hundred Forty Pesos (P1,740.00). not more than three (3) commissioners. The order fixing the
just compensation on the basis of the evidence before, and
Aggrieved, petitioner appealed directly to this Court, raising a
findings of, the commissioners would be final, too.
pure question of law. In a Resolution dated July 28, 1999,
the Court denied the Petition for Review "for being posted It should be stressed that the primary consideration in an
out of time on July 2, 1999, the due date being June 2, 1999, expropriation suit is whether the government or any of its
as the motion for extension of time to file petition was denied instrumentalities has complied with the requisites for the
in the resolution of July 14, 1999." taking of private property. Hence, the courts determine the
authority of the government entity, the necessity of the
expropriation, and the observance of due process. In the
ISSUE: Which court, MTC or RTC, has jurisdiction over main, the subject of an expropriation suit is the government's
cases for eminent domain or expropriation where the exercise of eminent domain, a matter that is incapable of
assessed value of the subject property is below Twenty pecuniary estimation.
Thousand (P20,000.00) Pesos?

HELD: The RTC as an expropriation suit is incapable of


pecuniary estimation.

The test to determine whether it is so was laid down by the


Court in this wise: "A review of the jurisprudence of this
Court indicates that 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, or where the money claim is
purely incidental to, or a consequence of, the principal relief
sought, like in suits to have the defendant perform his part of
the contract (specific performance) and in actions for
support, or for annulment of a judgment or to foreclose a
mortgage, this Court has considered such actions as cases
IRENE SANTE AND REYNALDO SANTE vs. HON. and respondent is entitled to amend her complaint as a
EDILBERTO T. CLARAVALL (G.R. No. 173915. February matter of right under the Rules.
22, 2010)

ISSUE: Did the RTC acquire jurisdiction over the case?


FACTS: On April 5, 2004, respondent filed before the RTC of
Baguio City a complaint for damages against petitioners. In
her complaint, docketed as Civil Case No. 5794-R,
respondent alleged that while she was inside the Police HELD: No.
Station of Natividad, Pangasinan, and in the presence of
Relatedly, Supreme Court Circular No. 21-99 was issued
other persons and police officers, petitioner Irene Sante
declaring that the first adjustment in jurisdictional amount of
uttered words, which when translated in English are as
first level courts outside of Metro Manila from P100,000.00 to
follows, "How many rounds of sex did you have last night
P200,000.00 took effect on March 20, 1999. Meanwhile, the
with your boss, Bert? You fuckin' bitch!" Bert refers to Albert
second adjustment from P200,000.00 to P300,000.00
Gacusan, respondent's friend and one (1) of her hired
became effective on February 22, 2004 in accordance with
personal security guards detained at the said station and
OCA Circular No. 65-2004 issued by the Office of the Court
who is a suspect in the killing of petitioners' close relative.
Administrator on May 13, 2004. Based on the foregoing,
Petitioners also allegedly went around Natividad,
there is no question that at the time of the filing of the
Pangasinan telling people that she is protecting and cuddling
complaint on April 5, 2004, the MTCC's jurisdictional amount
the suspects in the aforesaid killing. Thus, respondent
has been adjusted to P300,000.00.
prayed that petitioners be held liable to pay moral damages
in the amount of P300,000.00; P50,000.00 as exemplary But where damages is the main cause of action, should the
damages; P50,000.00 attorney's fees; P20,000.00 litigation amount of moral damages prayed for in the complaint be the
expenses; and costs of suit. sole basis for determining which court has jurisdiction or
should the total amount of all the damages claimed
Petitioners filed a Motion to Dismiss on the ground that it was
regardless of kind and nature, such as exemplary damages,
the Municipal Trial Court in Cities (MTCC) and not the RTC
nominal damages, and attorney's fees, etc., be used? In this
of Baguio, that had jurisdiction over the case. They argued
regard, Administrative Circular No. 09-94 19 is instructive:
that the amount of the claim for moral damages was not
more than the jurisdictional amount of P300,000.00, because xxx xxx xxx
the claim for exemplary damages should be excluded in
computing the total claim. On June 24, 2004, the trial court 2. The exclusion of the term "damages of whatever
denied the motion to dismiss citing our ruling in Movers- kind" in determining the jurisdictional amount under
Baseco Integrated Port Services, Inc. v. Cyborg Leasing Section 19 (8) and Section 33 (1) of B.P. Blg. 129,
Corporation. The trial court held that the total claim of as amended by R.A. No. 7691, applies to cases
respondent amounted to P420,000.00 which was above the where the damages are merely incidental to or a
jurisdictional amount for MTCCs outside Metro Manila. consequence of the main cause of action. However,
in cases where the claim for damages is the main
Aggrieved, petitioners filed on August 2, 2004, a Petition for cause of action, or one of the causes of action, the
Certiorari and Prohibition, docketed as CA-G.R. SP No. amount of such claim shall be considered in
85465, before the Court of Appeals. Meanwhile, on July 14, determining the jurisdiction of the court.
2004, respondent and her husband filed an Amended
Complaint increasing the claim for moral damages from It is clear, based on the allegations of the complaint, that
P300,000.00 to P1,000,000.00. Petitioners filed a Motion to respondent's main action is for damages. Hence, the other
Dismiss with Answer Ad Cautelam and Counterclaim, but the forms of damages being claimed by respondent, e.g.,
trial court denied their motion in an Order dated September exemplary damages, attorney's fees and litigation expenses,
17, 2004. are not merely incidental to or consequences of the main
action but constitute the primary relief prayed for in the
On January 23, 2006, the CA found that the RTC committed complaint.
grave abuse of discretion and granted their petition for
certiotari. The Court of Appeals held that the case clearly Lastly, we find no error, much less grave abuse of discretion,
falls under the jurisdiction of the MTCC as the allegations on the part of the Court of Appeals in affirming the RTC's
show that plaintiff was seeking to recover moral damages in order allowing the amendment of the original complaint from
the amount of P300,000.00, which amount was well within P300,000.00 to P1,000,000.00 despite the pendency of a
the jurisdictional amount of the MTCC. The Court of Appeals petition for certiorari filed before the Court of Appeals. While
added that the totality of claim rule used for determining it is a basic jurisprudential principle that an amendment
which court had jurisdiction could not be applied to the cannot be allowed when the court has no jurisdiction over the
instant case because plaintiff's claim for exemplary damages original complaint and the purpose of the amendment is to
was not a separate and distinct cause of action from her confer jurisdiction on the court , here, the RTC clearly had
claim of moral damages, but merely incidental to it. The jurisdiction over the original complaint and amendment of the
Court of Appeals additionally ruled that respondent can complaint was then still a matter of right.
amend her complaint by increasing the amount of moral
damages from P300,000.00 to P1,000,000.00, on the ground
that the trial court has jurisdiction over the original complaint
MARIETTA N. BARRIDO vs. LEONARDO V. NONATO (GR Municipal Trial Courts, and Municipal Circuit Trial
No. 176492. October 20, 2014) Courts shall exercise:

xxx xxx xxx

FACTS: In the course of the marriage of respondent (3) Exclusive original jurisdiction in all civil actions
Leonardo V. Nonato and petitioner Marietta N. Barrido, they which involve title to, or possession of, real
were able to acquire a property situated in Eroreco, Bacolod property, or any interest therein where the assessed
City, consisting of a house and lot, covered by Transfer value of the property or interest therein does not
Certificate of Title (TCT) No. T-140361. On March 15, 1996, exceed Twenty thousand pesos (P20,000.00) or, in
their marriage was declared void on the ground of civil actions in Metro Manila, where such assessed
psychological incapacity. Since there was no more reason to value does not exceed Fifty thousand pesos
maintain their co-ownership over the property, Nonato asked (P50,000.00) exclusive of interest, damages of
Barrido for partition, but the latter refused. Thus, on January whatever kind, attorney's fees, litigation expenses
29, 2003, Nonato filed a Complaint for partition before the and costs: Provided, That value of such property
Municipal Trial Court in Cities (MTCC) of Bacolod City, shall be determined by the assessed value of the
Branch 3. adjacent lots. (as amended by R.A. No. 7691)

The Bacolod MTCC rendered a Decision dated September Here, the subject property's assessed value was merely
17, 2003, applying Article 129 of the Family Code. It ruled in P8,080.00, an amount which certainly does not exceed the
this wise: required limit of P20,000.00 for civil actions outside Metro
Manila to fall within the jurisdiction of the MTCC. Therefore,
WHEREFORE, PREMISES CONSIDERED, the lower court correctly took cognizance of the instant case.
judgment is hereby rendered, ordering the conjugal
property of the former Spouses Leonardo and
Marietta Nonato, a house and lot covered by TCT
No. T-140361 located at Eroreco, Bacolod City,
which was their conjugal dwelling, adjudicated to
the defendant Marietta Nonato, the spouse with
whom the majority of the common children choose
to remain.

Nonato appealed the MTCC Decision before the RTC. On


July 21, 2004, the Bacolod RTC reversed the ruling of the
MTCC. It found that even though the MTCC aptly applied
Article 129 of the Family Code, it nevertheless made a
reversible error in adjudicating the subject property to
Barrido.

Upon appeal, the CA affirmed the RTC Decision on


November 16, 2006. It held that since the property's
assessed value was only P8,080.00, it clearly fell within the
MTCC's jurisdiction. Also, although the RTC erred in relying
on Article 129 of the Family Code, instead of Article 147, the
dispositive portion of its decision still correctly ordered the
equitable partition of the property. Barrido filed a Motion for
Reconsideration, which was, however, denied for lack of
merit.

ISSUE: THE HONORABLE COURT OF APPEALS ERRED


IN HOLDING THAT THE MTCC HAD JURISDICTION TO
TRY THE PRESENT CASE.

HELD: No. the MTCC has jurisdiction to take cognizance of


real actions or those affecting title to real property, or for the
recovery of possession, or for the partition or condemnation
of, or foreclosure of a mortgage on real property. Section 33
of Batas Pambansa Bilang 129 provides:

Section 33. Jurisdiction of Metropolitan Trial Courts,


Municipal Trial Courts and Municipal Circuit Trial
Courts in civil cases. Metropolitan Trial Courts,
MICHAEL SEBASTIAN vs. ANNABEL LAGMAY NG (G.R. March 31, 2004, the CA rendered its decision granting the
No. 164594. April 22, 2015) petition, and reversing the RTC's decision. The CA declared
that the "appropriate local trial court" stated in Section 2,
Rule VII of the Implementing Rules of R.A. No. 7160 refers to
the municipal trial courts. Thus, contrary to Michael's
FACTS: Sometime in 1997, Angelita Lagmay (Angelita), contention, the MCTC has jurisdiction to enforce any
acting as representative and attorney-in-fact of her daughter settlement or arbitration award, regardless of the amount
Annabel Lagmay Ng (Annabel), filed a complaint before the involved.
Barangay Justice of Siclong, Laur, Nueva Ecija. She sought
to collect from Michael the sum of P350,000.00 that Annabel
sent to Michael. She claimed that Annabel and Michael were
once sweethearts, and that they agreed to jointly invest their ISSUE: Whether the MCTC, through Angelita's motion for
financial resources to buy a truck. She alleged that while execution, is expressly authorized to enforce the kasunduan
Annabel was working in Hongkong, Annabel sent Michael under Section 417 of the Local Government Code?
the amount of P350,000.00 to purchase the truck. However,
after Annabel and Michael's relationship has ended, Michael
allegedly refused to return the money to Annabel, prompting
the latter to bring the matter before the Barangay Justice. HELD: Yes.

On July 9, 1997, the parties entered into an amicable A simple reading of Section 417 of the Local Government
settlement, evidenced by a document denominated as Code readily discloses the two-tiered mode of enforcement
"kasunduan" wherein Michael agreed to pay Annabel the of an amicable settlement. The provision reads:
amount of P250,000.00 on specific dates. The kasunduan
Section 417. Execution. The amicable settlement
was signed by Angelita (on behalf of Annabel), Michael, and
or arbitration award may be enforced by execution
the members of the pangkat ng tagapagkasundo.
by the lupon within six (6) months from the date of
After about one and a half years from the date of the the settlement. After the lapse of such time, the
execution of the kasunduan or on January 15, 1999, Angelita settlement may be enforced by action in the
filed with the Municipal Circuit Trial Court (MCTC) of Laur appropriate city or municipal court.
and Gabaldon, Nueva Ecija, a Motion for Execution of the
The second mode of enforcement, on the other hand, is
kasunduan. Michael moved for the dismissal of the Motion
judicial in nature and could only be resorted to through the
for Execution, citing as a ground Angelita's alleged violation
institution of an action in a regular form before the proper
of Section 15, Rule 13 of the 1997 Rules of Civil Procedure.
City/Municipal Trial Court. The proceedings shall be
On January 17, 2000, the MCTC rendered a decision in favor
governed by the provisions of the Rules of Court.
of Annabel.
Indisputably, Angelita chose to enforce the kasunduan under
Michael filed an appeal with the RTC arguing that the MCTC the second mode and filed a motion for execution, which was
committed grave abuse of discretion in prematurely deciding docketed as Special Proceedings No. 45-99.
the case. Michael also pointed out that a hearing was
A perusal of the motion for execution, however, shows that it
necessary for the petitioner to establish the genuineness and
contains the material requirements of an initiatory action.
due execution of the kasunduan. In its November 13, 2000
First, the motion is sufficient in form and substance. It is
Decision, 6 the RTC, Branch 40 of Palayan City upheld the
complete with allegations of the ultimate facts constituting
MCTC decision, finding Michael liable to pay Annabel the
the cause of action; the names and residences of the plaintiff
sum of P250,000.00. It held that Michael failed to assail the
and the defendant; it contains the prayer for the MCTC to
validity of the kasunduan, or to adduce any evidence to
order the execution of the kasunduan; and there was also a
dispute Annabel's claims or the applicability of the
verification and certification against forum shopping.
Implementing Rules and Regulations of R.A. No. 7160.
It is well-settled that what are controlling in determining the
Michael filed a Motion for Reconsideration arguing that: (i) an
nature of the pleading are the allegations in the body and not
amicable settlement or arbitration award can be enforced by
the caption. Thus, the motion for execution that Angelita filed
the Lupon within six (6) months from date of settlement or
was intended to be an initiatory pleading or an original action
after the lapse of six (6) months, by ordinary civil action in
that is compliant with the requirement under Section 3, Rule
the appropriate City or Municipal Trial Court and not by a
6 of the Rules of Court that the complaint should allege the
mere Motion for execution; and (ii) the MCTC does not have
plaintiff's cause of action and the names and residences of
jurisdiction over the case since the amount of P250,000.00
the plaintiff and the defendant. Angelita's motion could
(as the subject matter of the kasunduan) is in excess of
therefore be treated as an original action, and not merely as
MCTC's jurisdictional amount of P200,000.00. In its March
a motion/special proceeding. For this reason, Annabel has
13, 2001 Order, the RTC granted Michael's Motion for
filed the proper remedy prescribed under Section 417 of the
Reconsideration, and ruled that there is merit in the
Local Government Code.
jurisdictional issue he raised. It dismissed Angelita's Motion
for Execution, and set aside the MCTC Decision. The Court also finds that the CA correctly upheld the
MCTC's jurisdiction to enforce any settlement or arbitration
Angelita moved for the reconsideration of the March 13,
award issued by the Lupon. We again draw attention to the
2001 Order, but the motion was subsequently denied.
provision of Section 417 of the Local Government Code that
Aggrieved, she filed a Petition for Review with the CA. On
after the lapse of the six (6) month period from the date of
the settlement, the agreement may be enforced by action in
the appropriate city or municipal court. The law, as written,
unequivocally speaks of the " appropriate city or municipal
court" as the forum for the execution of the settlement or
arbitration award issued by the Lupon. Notably, in expressly
conferring authority over these courts, Section 417 made no
distinction with respect to the amount involved or the nature
of the issue involved. Thus, there can be no question that the
law's intendment was to grant jurisdiction over the
enforcement of settlement/arbitration awards to the city or
municipal courts regardless of the amount.
MANUEL LUIS C. GONZALES and FRANCIS MARTIN D. At the outset, the Court finds Branch 276 to have correctly
GONZALES vs. GJH LAND, INC. (formerly known as S.J. categorized Civil Case No. 11-077 as a commercial case,
LAND, INC.) (G.R. No. 202664. November 10, 2015) more particularly, an intra-corporate dispute, considering that
it relates to petitioners' averred rights over the shares of
stock offered for sale to other stockholders, having paid the
same in full. Applying the relationship test and the nature of
FACTS: On August 4, 2011, petitioners Manuel Luis C. the controversy test, the suit between the parties is clearly
Gonzales and Francis Martin D. Gonzales (petitioners) filed a rooted in the existence of an intra-corporate relationship and
Complaint for "Injunction with prayer for Issuance of Status pertains to the enforcement of their correlative rights and
Quo Order, Three (3) and Twenty (20)-Day Temporary obligations under the Corporation Code and the internal and
Restraining Orders, and Writ of Preliminary Injunction with intra-corporate regulatory rules of the corporation, 24 hence,
Damages" against respondents GJH Land, Inc. (formerly intra-corporate, which should be heard by the designated
known as S.J. Land, Inc.), Chang Hwan Jang, Sang Rak Special Commercial Court as provided under A.M. No. 03-
Kim, Mariechu N. Yap, and Atty. Roberto P. Mallari II 03-03-SC 25 dated June 17, 2003 in relation to Item 5.2,
(respondents) before the RTC of Muntinlupa City seeking to Section 5 of RA 8799.
enjoin the sale of S.J. Land, Inc.'s shares which they
purportedly bought from S.J. Global, Inc. on February 1, Pertinent to this case is RA 8799 which took effect on August
2010. Essentially, petitioners alleged that the subscriptions 8, 2000. By virtue of said law, jurisdiction over cases
for the said shares were already paid by them in full in the enumerated in Section 5 28 of Presidential Decree No. 902-
books of S.J. Land, Inc., but were nonetheless offered for A was transferred from the Securities and Exchange
sale on July 29, 2011 to the corporation's stockholders, Commission (SEC) to the RTCs, being courts of general
hence, their plea for injunction. jurisdiction. The legal attribution of Regional Trial Courts as
courts of general jurisdiction stems from Section 19 (6),
After filing their respective answers to the complaint, Chapter II of Batas Pambansa Bilang (BP) 129, known as
respondents filed a motion to dismiss on the ground of lack "The Judiciary Reorganization Act of 1980". To clarify, the
of jurisdiction over the subject matter, pointing out that the word "or" in Item 5.2, Section 5 of RA 8799 was intentionally
case involves an intra-corporate dispute and should, thus, be used by the legislature to particularize the fact that the
heard by the designated Special Commercial Court of phrase "the Courts of general jurisdiction" is equivalent to the
Muntinlupa City. In an Order 14 dated April 17, 2012, Branch phrase "the appropriate Regional Trial Court." In other
276 granted the motion to dismiss filed by respondents. It words, the jurisdiction of the SEC over the cases
found that the case involves an intra-corporate dispute that is enumerated under Section 5 of PD 902-A was transferred to
within the original and exclusive jurisdiction of the RTCs the courts of general jurisdiction, that is to say (or, otherwise
designated as Special Commercial Courts. It pointed out that known as), the proper Regional Trial Courts.
the RTC of Muntinlupa City, Branch 256 (Branch 256) was
specifically designated by the Court as the Special Consistent with the foregoing, history depicts that when the
Commercial Court, hence, Branch 276 had no jurisdiction transfer of SEC cases to the RTCs was first implemented,
over the case and cannot lawfully exercise jurisdiction on the they were transmitted to the Executive Judges of the RTCs
matter, including the issuance of a Writ of Preliminary for raffle between or among its different branches, unless a
Injunction. specific branch has been designated as a Special
Commercial Court, in which instance, the cases were
Dissatisfied, petitioners filed a motion for reconsideration, transmitted to said branch. It was only on November 21,
arguing that they filed the case with the Office of the Clerk of 2000 that the Court designated certain RTC branches to try
Court of the RTC of Muntinlupa City which assigned the and decide said SEC cases without, however, providing for
same to Branch 276 by raffle. As the raffle was beyond their the transfer of the cases already distributed to or filed with
control, they should not be made to suffer the consequences the regular branches thereof. Thus, on January 23, 2001, the
of the wrong assignment of the case, especially after paying Court issued SC Administrative Circular No. 08-2001 38
the filing fees in the amount of P235,825.00 that would be for directing the transfer of said cases to the designated courts
naught if the dismissal is upheld. (commercial SEC courts). Later, or on June 17, 2003, the
Court issued A.M. No. 03-03-03-SC consolidating the
commercial SEC courts and the intellectual property courts in
ISSUE: whether or not Branch 276 of the RTC of Muntinlupa one RTC branch in a particular locality, i.e., the Special
City erred in dismissing the case for lack of jurisdiction over Commercial Court, to streamline the court structure and to
the subject matter promote expediency. Accordingly, the RTC branch so
designated was mandated to try and decide SEC cases, as
(The present controversy lies, however, in the procedure to well as those involving violations of intellectual property
be followed when a commercial case such as the instant rights, which were, thereupon, required to be filed in the
intra-corporate dispute has been properly filed in the Office of the Clerk of Court in the official station of the
official station of the designated Special Commercial Court designated Special Commercial Courts.
but is, however, later wrongly assigned by raffle to a regular
branch of that station.) The objective behind the designation of such specialized
courts is to promote expediency and efficiency in the
exercise of the RTCs' jurisdiction over the cases enumerated
under Section 5 of PD 902-A. Such designation has nothing
HELD: Yes. to do with the statutory conferment of jurisdiction to all RTCs
under RA 8799 since in the first place, the Court cannot
enlarge, diminish, or dictate when jurisdiction shall be Commercial Courts in the scenarios stated above, the re-
removed, given that the power to define, prescribe, and raffling of an ordinary civil case in this instance to all courts is
apportion jurisdiction is, as a general rule, a matter of permissible due to the fact that a particular branch which has
legislative prerogative. been designated as a Special Commercial Court does not
shed the RTC's general jurisdiction over ordinary civil cases
Here, petitioners filed a commercial case, i.e., an intra- under the imprimatur of statutory law.
corporate dispute, with the Office of the Clerk of Court in the
RTC of Muntinlupa City, which is the official station of the Furthermore, the Court hereby RESOLVES that henceforth,
designated Special Commercial Court, in accordance with the following guidelines shall be observed:
A.M. No. 03-03-03-SC. It is, therefore, from the time of such
filing that the RTC of Muntinlupa City acquired jurisdiction 1. If a commercial case filed before the proper RTC is
over the subject matter or the nature of the action. wrongly raffled to its regular branch, the proper courses of
Unfortunately, the commercial case was wrongly raffled to a action are as follows:
regular branch, i.e. , Branch 276, instead of being assigned
44 to the sole Special Commercial Court in the RTC of 1.1 If the RTC has only one branch designated as a
Muntinlupa City, which is Branch 256 . This error may have Special Commercial Court, then the case shall be
been caused by a reliance on the complaint's caption, i.e., referred to the Executive Judge for re-docketing as
"Civil Case for Injunction with prayer for Status Quo Order, a commercial case, and thereafter, assigned to the
TRO and Damages," which, however, contradicts and more sole special branch;
importantly, cannot prevail over its actual allegations that
1.2 If the RTC has multiple branches designated as
clearly make out an intra-corporate dispute.
Special Commercial Courts, then the case shall be
The Court nonetheless deems that the erroneous raffling to a referred to the Executive Judge for re-docketing as
regular branch instead of to a Special Commercial Court is a commercial case, and thereafter, raffled off
only a matter of procedure that is, an incident related to among those special branches; and
the exercise of jurisdiction and, thus, should not negate
1.3 If the RTC has no internal branch designated as
the jurisdiction which the RTC of Muntinlupa City had already
a Special Commercial Court, then the case shall be
acquired. In such a scenario, the proper course of action was
referred to the nearest RTC with a designated
not for the commercial case to be dismissed; instead, Branch
Special Commercial Court branch within the judicial
276 should have first referred the case to the Executive
region. Upon referral, the RTC to which the case
Judge for re-docketing as a commercial case; thereafter, the
was referred to should re-docket the case as a
Executive Judge should then assign said case to the only
commercial case, and then: (a) if the said RTC has
designated Special Commercial Court in the station, i.e. ,
only one branch designated as a Special
Branch 256.
Commercial Court, assign the case to the sole
Note that the procedure would be different where the RTC special branch; or (b) if the said RTC has multiple
acquiring jurisdiction over the case has multiple special branches designated as Special Commercial
commercial court branches; in such a scenario, the Courts, raffe off the case among those special
Executive Judge, after re-docketing the same as a branches.
commercial case, should proceed to order its re-raffling
2. If an ordinary civil case filed before the proper RTC is
among the said special branches. Meanwhile, if the RTC
wrongly raffled to its branch designated as a Special
acquiring jurisdiction has no branch designated as a Special
Commercial Court, then the case shall be referred to the
Commercial Court, then it should refer the case to the
Executive Judge for re-docketing as an ordinary civil case.
nearest RTC with a designated Special Commercial Court
Thereafter, it shall be raffled off to all courts of the same RTC
branch within the judicial region. Upon referral, the RTC to
(including its designated special branches which, by statute,
which the case was referred to should re-docket the case as
are equally capable of exercising general jurisdiction same
a commercial case, and then: (a) if the said RTC has only
as regular branches), as provided for under existing rules.
one branch designated as a Special Commercial Court,
assign the case to the sole special branch; or (b) if the said 3. All transfer/raffle of cases is subject to the payment of the
RTC has multiple branches designated as Special appropriate docket fees in case of any difference. On the
Commercial Courts, raffle off the case among those special other hand, all docket fees already paid shall be duly
branches. credited, and any excess, refunded.
For further guidance, the Court finds it apt to point out that 4. Finally, to avert any future confusion, the Court requires
the same principles apply to the inverse situation of ordinary that all initiatory pleadings state the action's nature both in its
civil cases filed before the proper RTCs but wrongly raffled to caption and body. Otherwise, the initiatory pleading may,
its branches designated as Special Commercial Courts. In upon motion or by order of the court motu proprio, be
such a scenario, the ordinary civil case should then be dismissed without prejudice to its re-filing after due
referred to the Executive Judge for re-docketing as an rectification. This last procedural rule is prospective in
ordinary civil case; thereafter, the Executive Judge should application.
then order the raffling of the case to all branches of the same
RTC, subject to limitations under existing internal rules, and 5. All existing rules inconsistent with the foregoing are
the payment of the correct docket fees in case of any deemed superseded.
difference. Unlike the limited assignment/raffling of a
commercial case only to branches designated as Special