1
JURISDICTION
CASE TITLE
IRENE SANTE vs. HON. EDILBERTO T.
CLARAVALL and VITA N.
KALASHIAN
G.R. No. 173915
February 22, 2010
WHEREFORE, the petition is
DENIED, for lack of merit. The
Decision and Resolution of the
Court of Appeals dated January
31, 2006 and June 23, 2006,
respectively, are AFFIRMED. The
Regional Trial Court of Baguio City,
Branch 60
is DIRECTED to continue with the
trial proceedings in Civil Case No.
5794-R with deliberate dispatch.
ISSUE | DOCTRINE | APPLICATION
1. WON RTC acquire jurisdiction over the case? YES.
2. WON RTC commit grave abuse of discretion in allowing the
amendment of the complaint? NO.
 In cases where the claim for damages is the main cause of action, or
one of the causes of action, the amount of such claim shall be
considered in determining the jurisdiction of the court.
 Where it is clear, based on the allegations of the complaint, that the
main action is for damages, the other forms of damages being
claimed e.g., exemplary damages, attorney’s fees and litigation
expenses, are not merely incidental to or consequences of the main
action but constitute the primary relief prayed for in the complaint.
 It is a basic jurisprudential principle that an amendment cannot be
allowed when the court has no jurisdiction over the original complaint
and the purpose of the amendment is to confer jurisdiction on the
court.
We deny the petition
 Section 19(8) of Batas Pambansa Blg. 129,17 as amended by Republic
Act No. 7691. Relatedly, Supreme Court Circular No. 21-99 was issued
declaring that the first adjustment in jurisdictional amount of first level
courts outside of Metro Manila from P100,000.00 to P200,000.00 took
effect on March 20, 1999.
 Meanwhile, the second adjustment from P200,000.00 to P300,000.00
became effective on February 22, 2004 in accordance with OCA
Circular No. 65-2004 issued by the Office of the Court Administrator on
May 13, 2004.
 Based on the foregoing, there is no question that at the time of the
filing of the complaint on April 5, 2004, the MTCC’s jurisdictional
amount has been adjusted to P300,000.00.
 But where damages is the main cause of action, should the amount of
moral damages prayed for in the complaint be the sole basis for
determining which court has jurisdiction or should the total amount of
all the damages claimed regardless of kind and nature, such as
exemplary damages, nominal damages, and attorney’s fees, etc., be
used?
 In this regard, Administrative Circular No. 09-94 is instructive:
“x x x x
2. The exclusion of the term “damages of whatever kind” in determining
the jurisdictional amount under Section 19 (8) and Section 33 (1) of B.P.
Blg. 129, as amended by R.A. No. 7691, applies to cases where the
FACTS | NOTES
 KALASHIAN filed before the RTC (baguio) a complaint for
damages against SANTE on the ground of SANTES
remarks against KALASHIAN in the police station, which
uttered the words of her (KALASHIAN) having sex with
one ALBERT, KALASHIAN’s friend, hired security and a
suspect in killing SANTE’s close relative.
 KALASHIAN prayed for the moral damages (300,000),
exemplary (50,000); attorney’s fees (50,000) and litigation
expenses (20,000)
 2 CA cases,
 SANTE filed a MOTION TO DISMISS on the ground that it
was MTCC and not RTC, which has the jurisdiction over
the case.
o ARGUMENT: the claim for moral damages was not
more than 300,000 and the exemplary damages
should not be included in the computation of total
claim as it is merely incidental.
o RTC denied the MoTDis ruling that the total claim is
420,000 (under the jurisdiction of RTC)
o APPEAL was made with the CA.
 During pendency, the claim of KALASHIAN was
amended from 300,000 to 1Million. Motion to dismiss was
filed but denied by RTC
 SANTE filed Certiorari and prohibition with CA.
o ARGUMENT: RTC committed grave abuse of
discretion in allowing the amendment.
o 1st CA – MTCC of baguio has jurisdiction; The Court of
Appeals added that the totality of claim rule used
for determining which court had jurisdiction could
not be applied to the instant case because plaintiff’s
claim for exemplary damages was not a separate
and distinct cause of action from her claim of moral
damages, but merely incidental to it.
o 2ND CA – affirmed the denial of RTC of motion to
dismiss in the amendment of claim. In the said
decision, the appellate court held that the total or
aggregate amount demanded in the complaint
constitutes the basis of jurisdiction. The Court of
Appeals did not find merit in petitioners’ posture that
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damages are merely incidental to or a consequence of the main cause the claims for exemplary damages and attorney’s
of action. However, in cases where the claim for damages is the main fees are merely incidental to the main cause and
cause of action, or one of the causes of action, the amount of such claim should not be included in the computation of the
shall be considered in determining the jurisdiction of the court.” total claim.
 In the instant case, the complaint filed in Civil Case No. 5794-R is for HENCE, this case,
the recovery of damages for the alleged malicious acts of petitioners.
The complaint principally sought an award of moral and exemplary KALASHIAN claims: that the nature of her complaint is for
damages, as well as attorney’s fees and litigation expenses, for the recovery of damages. As such, the totality of the claim for
alleged shame and injury suffered by respondent by reason of damages, including the exemplary damages as well as the
petitioners’ utterance while they were at a police station in other damages alleged and prayed in the complaint, such
Pangasinan. It is settled that jurisdiction is conferred by law based on as attorney’s fees and litigation expenses, should be
the facts alleged in the complaint since the latter comprises a concise included in determining jurisdiction. The total claim being
statement of the ultimate facts constituting the plaintiff’s causes of P420,000.00, the RTC has jurisdiction over the complaint.
action.
 It is clear, based on the allegations of the complaint, that
respondent’s main action is for damages. Hence, the other forms of
damages being claimed by respondent, e.g., exemplary damages,
attorney’s fees and litigation expenses, are not merely incidental to or
consequences of the main action but constitute the primary relief
prayed for in the complaint.
 Lastly, we find no error, much less grave abuse of discretion, on the
part of the Court of Appeals in affirming the RTC’s order allowing the
amendment of the original complaint from P300,000.00 to
P1,000,000.00 despite the pendency of a petition for certiorari filed
before the Court of Appeals. While it is a basic jurisprudential principle
that an amendment cannot be allowed when the court has no
jurisdiction over the original complaint and the purpose of the
amendment is to confer jurisdiction on the court, here, the RTC clearly
had jurisdiction over the original complaint and amendment of the
complaint was then still a matter of right.
Sebastian vs. Ng  WON MCTC has jurisdiction to execute the KASUNDUAN irrespective of  In 1997, Angelita Lagmay (Angelita), acting as
amount, YES. representative and attorney-in-fact of her daughter
G.R. No. 164594  Under Section 416 of the Local Government Code (LGC), the Annabel Lagmay Ng (Annabel), filed a complaint before
April 22, 2015 amicable settlement and arbitration award shall have the force and the Barangay Justice of Siclong, Laur, Nueva Ecija
effect of a final judgment of a court upon the expiration of ten (10)  She sought to collect from Michael the sum of
WHEREFORE, premises days from the date of its execution, unless the settlement or award has P350,000.00 that Annabel sent to Michael.
considered, we hereby DENY the been repudiated or a petition to nullify the award has been filed  ANGELITA claim that:
petitioner’s petition for review before the proper city or municipal court. 1. Annabel and Michael were once sweethearts
on certiorari, and AFFIRM the The MCTC has the authority and jurisdiction to enforce 2. they agreed to jointly invest their financial resources
March 31, 2004 Decision of the the kasunduan regardless of the amount involved. to buy a truck
Court of Appeals in C.A.-G.R. S.P. 3. while Annabel was working in Hongkong, Annabel
No. 65450. The Court also finds that the CA correctly upheld the MCTC’s sent Michael the amount of P350,000.00 to purchase

Angelita Lagmay is ORDERED to
pay the proper docket fees to be
computed by the Clerk of Court of
the Municipal Circuit Trial Court of
Laur and Gabaldon, Nueva Ecija,
with due consideration of what she
had paid when her motion for
execution was docketed as a
special proceeding.
SO ORDERED.
jurisdiction to enforce any settlement or arbitration award issued by
the Lupon.
We again draw attention to the provision of Section 417 of the Local
Government Code that after the lapse of the six (6) month period from
the date of the settlement, the agreement may be enforced by action in
the appropriate city or municipal court.
The law, as written, unequivocally speaks of the “appropriate city or
municipal court” as the forum for the execution of the settlement or
arbitration award issued by the Lupon. Notably, in expressly conferring
authority over these courts, Section 417 made no distinction with respect
to the amount involved or the nature of the issue involved. Thus, there
can be no question that the law’s intendment was to grant jurisdiction
over the enforcement of settlement/arbitration awards to the city or
municipal courts the regardless of the amount. A basic principle of
interpretation is that words must be given their literal meaning and
applied without attempted interpretation where the words of a statute
are clear, plain and free from ambiguity.
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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.
 On July 9, 1997, the parties entered into an amicable
settlement, evidenced by a document denominated as
“kasunduan”4 wherein Michael agreed to pay Annabel
the amount of P250,000.00 on specific dates.
 Angelita alleged that the kasunduan was not
repudiated within a period of ten (10) days from the
settlement, in accordance with the Katarungang
Pambarangay Law embodied in the Local Government
Code and Section 14 of its Implementing Rules.
 When Michael failed to honor the kasunduan, Angelita
brought the matter back to the Barangay, but
the Barangay Captain failed to enforce the kasunduan,
and instead, issued a Certification to File Action.
 After about one and a half years from the date of the
execution of the kasunduan or on January 15, 1999,
Angelita filed with the Municipal Circuit Trial Court
(MCTC) a Motion for Execution of the kasunduan.
 MCTC case: MoTDis by MICHAEL but MCTC ruled in favor
of ANNABEL.
 Appeal to RTC: upheld MCTC decision
 MR with RTC: ruled in favor of MICHAEL (granted the MR)
 MR with RTC from ANNABEL: denied.
 PetRev with CA: initially dismissed then MR upon
attaching Affidavit of Service. GRANTED the motion and
set aside RTC. (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
contention, the MCTC has jurisdiction to enforce any
settlement or arbitration award, regardless of the
amount involved.)
 HENCE, this case.
 MICHAEL argued that the amount involved in the
kasunduan was beyond the 200,000 jurisdictional
amount of MCTC. Thus, it has no jurisdiction.

Barrido vs. Nonato
G.R. No. 176492
October 20, 2014
WHEREFORE, premises considered,
the petition is DENIED. The Decision
of the Court of Appeals, dated
November 16, 2006, as well as its
Resolution dated January 24, 2007
in C.A.-G.R. S.P. No. 00235, are
hereby AFFIRMED.
Barangay San Roque, Talisay, Cebu
vs. Heirs of Francisco Pastor
G.R. No. 138896
June 20, 2000
WHEREFORE, the Petition is hereby
GRANTED and the assailed Orders
SET ASIDE. The Regional Trial Court is
directed to HEAR the case. No
costs.
 WON MTCC has jurisdiction. YES.
 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.
 Contrary to Barrido’s contention, 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, Municipal Trial Courts, and Municipal Circuit Trial Courts
shall exercise:
 xxxx
 (3) Exclusive original jurisdiction in all civil actions which involve title
to, or possession of, real property, or any interest therein where
the assessed value of the property or interest therein does not exceed
Twenty thousand pesos (P20,000.00)or, in civil actions in Metro Manila,
where such assessed value does not exceed Fifty thousand pesos
(P50,000.00) exclusive of interest, damages of whatever kind,
attorney’s fees, litigation expenses and costs: Provided, That value of
such property shall be determined by the assessed value of the
adjacent lots. (as amended by R.A. No. 7691)
 Here, the subject property’s assessed value was merely P8,080.00, an
amount which certainly does not exceed the required limit of
P20,000.00 for civil actions outside Metro Manila to fall within the
jurisdiction of the MTCC. Therefore, the lower court correctly took
cognizance of the instant case.
 Whether RTC or MTC has jurisdiction over eminent domain cases when
the value of the property is less than 20,000. RTC.
An expropriation suit is incapable of pecuniary estimation. Accordingly, it
falls within the jurisdiction of the regional trial courts, regardless of the
value of the subject property.
 An expropriation suit is incapable of pecuniary estimation, and falls
within the jurisdiction of the Regional Trial Courts.
 It should be stressed that the primary consideration in an expropriation
suit is whether the government or any of its instrumentalities has
complied with the requisites for the taking of private property.
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 In the course of the marriage of respondent Leonardo V.
Nonato and petitioner Marietta N. Barrido, they were
able to acquire a property situated in Eroreco, Bacolod
City, consisting of a house and lot
 On March 15, 1996, their marriage was declared void on
the ground of psychological incapacity.
 Since there was no more reason to maintain their co-
ownership over the property, Nonato asked Barrido for
partition, but the latter refused.
 Nonato filed a Complaint for partition before the
Municipal Trial Court in Cities (MTCC) of Bacolod City
 Barrido moved for the dismissal of the complaint
because the MTCC lacked jurisdiction, the partition case
being an action incapable of pecuniary estimation.
 MTCC ruled in favor of BARRIDO.
 NONATO appealed with the RTC.
 RTC reversed MTCC on the ground of reversible error in
adjudicating the property to BARRIDO.
 Upon appeal CA affirmed the RTC decision and ruled
that the assessed value of the property is 8,080.00 which
is under the MTCC jurisdiction.
 HENCE, this case.
BARRIDO claims that MTCC has jurisdiction over the partition
case.
 Petitioner filed before the Municipal Trial Court (MTC) a
Complaint to expropriate a property of the respondents.
 In an Order, the MTC dismissed the Complaint on the
ground of lack of jurisdiction.
 It reasoned that “[e]minent domain is an exercise of the
power to take private property for public use after
payment of just compensation. In an action for eminent
domain, therefore, the principal cause of action is the
exercise of such power or right. The fact that the action
also involves real property is merely incidental. An action
for eminent domain is therefore within the exclusive
original jurisdiction of the Regional Trial Court and not

 We agree with the petitioner that 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 where the subject of the litigation may not be
estimated in 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 deemed to be more within the competence of courts of first
instance, which were the lowest courts of record at the time that the first
organic laws of the Judiciary were enacted allocating jurisdiction
 In the present case, an expropriation suit does not involve the
recovery of a sum of money. Rather, it deals with the exercise by the
government of its authority and right to take private property for
public use.
 In National Power Corporation v. Jocson, the Court ruled that
expropriation proceedings have two phases:
1. “The first is concerned with the determination of the authority of
the plaintiff to exercise the power of eminent domain and the
propriety of its exercise in the context of the facts involved in the
suit.
2. “The second phase of the eminent domain action is concerned
with the determination by the court of ‘the just compensation for
the property sought to be taken.’
 It should be stressed that the primary consideration in an expropriation
suit is whether the government or any of its instrumentalities has
complied with the requisites for the taking of private property. Hence,
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with this Court.”
 The RTC also dismissed the Complaint when filed before
it, holding that an action for eminent domain affected
title to real property; hence, the value of the property to
be expropriated would determine whether the case
should be filed before the MTC or the RTC.
 Concluding that the action should have been filed
before the MTC since the value of the subject property
was less than P20,000
 Aggrieved, petitioner appealed directly to this Court,
raising a pure question of law.
 In a Resolution dated July 28, 1999, the Court denied the
Petition for Review “for being posted out of time.
 In a subsequent Resolution dated October 6, 1999, the
Court reinstated the Petition
BRGY. SAN ROQUE argued that:
 the present action involves the exercise of the right to
eminent domain, and that such right is incapable of
pecuniary estimation. (under Section 19 (1) of BP 129,
which provides that RTCs shall exercise exclusive original
jurisdiction over “all civil actions in which the subject of
the litigation is incapable of pecuniary estimation; x x x.”)
PASTOR claims that:
 the Complaint for Eminent Domain affects the title to or
possession of real property. Thus, they argue that the
case should have been brought before the MTC ( under
BP 129 as amended by Section 3 (3) of RA 7691. This law
provides that MTCs shall have exclusive original
jurisdiction over all civil actions that involve title to or
possession of real property, the assessed value of which
does not exceed twenty thousand pesos or, in civil
actions in Metro Manila, fifty thousand pesos exclusive of
interest, damages of whatever kind, attorney’s fees,
litigation expenses and costs)
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the courts determine the authority of the government entity, the

necessity of the expropriation, and the observance of due process.
 In the main, the subject of an expropriation suit is the government’s
exercise of eminent domain, a matter that is incapable of pecuniary
estimation.
 True, the value of the property to be expropriated is estimated in
monetary terms, for the court is duty-bound to determine the just
compensation for it. This, however, is merely incidental to the
expropriation suit. Indeed, that amount is determined only after the
court is satisfied with the propriety of the expropriation.
 Verily, the Court held in Republic of the Philippines v. Zurbano that
“condemnation proceedings are within the jurisdiction of Courts of
First Instance,” the forerunners of the regional trial courts. The said case
was decided during the effectivity of the Judiciary Act of 1948 which,
like BP 129 in respect to RTCs, provided that courts of first instance had
original jurisdiction over “all civil actions in which the subject of the
litigation is not capable of pecuniary estimation.”
 The 1997 amendments to the Rules of Court were not intended to
change these jurisprudential precedents.
 We are not persuaded by respondents’ argument that the present
action involves the title to or possession of a parcel of land. They cite
the observation of retired Justice Jose Y. Feria
 Their reliance is misplaced. Justice Feria sought merely to distinguish
between real and personal actions. His discussion on this point
pertained to the nature of actions, not to the jurisdiction of courts. In
fact, in his pre-bar lectures, he emphasizes that jurisdiction over
eminent domain cases is still within the RTCs under the 1997 Rules.
 To emphasize, the question in the present suit is whether the
government may expropriate private property under the given set of
circumstances. The government does not dispute respondents’ title to
or possession of the same. Indeed, it is not a question of who has a
better title or right, for the government does not even claim that it has
a title to the property. It merely asserts its inherent sovereign power to
“‘appropriate and control individual property for the public benefit, as
the public necessity, convenience or welfare may demand.”

Gonzales vs. GJH Land, Inc.
(formerly S.J. Land, Inc.)
G.R. No. 202664
November 10, 2015
 WON RTC Branch 276 is correct in dismissing the case for lack of
jurisdiction as the procedure in this case. NO.
 Special Commercial Courts; Jurisdiction; Applying the relationship test
and the nature of the controversy test, the suit between the parties is
clearly rooted in the existence of an intra-corporate relationship and
pertains to the enforcement of their correlative rights and obligations
 On August 4, 2011, petitioners Manuel Luis C.
Gonzales4 and Francis Martin D. Gonzales (petitioners)
filed a Complaint for “Injunction with prayer for Issuance
of Status Quo Order, Temporary Restraining Orders, and
Writ of Preliminary Injunction with Damages” against
respondents GJH Land, Inc.

In fine, Branch 276’s dismissal of
Civil Case No. 11-077 is set aside
and the transfer of said case to
Branch 256, the designated Special
Commercial Court of the same RTC
of Muntinlupa City, under the
parameters above explained, is
hereby ordered.
WHEREFORE, the petition
is GRANTED. The Orders dated April
17, 2012 and July 9, 2012 of the
Regional Trial
Court (RTC) of Muntinlupa City,
Branch 276 in Civil Case No. 11-077
are hereby REVERSED and SET
ASIDE. Civil Case No. 11-077
is REFERRED to the Executive Judge
of the RTC of Muntinlupa City for re-
docketing as a commercial case.
Thereafter, the Executive Judge
shall ASSIGN said case to Branch
256, the sole designated Special
Commercial Court in the RTC of
Muntinlupa City, which
is ORDERED to resolve the case with
reasonable dispatch. In this regard,
the Clerk of Court of said RTC
shall DETERMINE the appropriate
amount of docket fees and, in so
doing, ORDER the payment of any
difference or, on the other hand,
refund any excess.
under the Corporation Code and the internal and intra-corporate
regulatory rules of the corporation, hence, intra-corporate, which
should be heard by the designated Special Commercial Court as
provided under A.M. No. 03-03-03-SC dated June 17, 2003 in relation
to Item 5.2, Section 5 of Republic Act (RA) No. 8799.
 By virtue of Republic Act (RA) No. 8799, jurisdiction over cases
enumerated in Section 5 of Presidential Decree (PD) No. 902-A was
transferred from the Securities and Exchange Commission (SEC) to the
Regional Trial Courts (RTCs), being courts of general jurisdiction.
 On June 17, 2003, the Supreme Court (SC) issued A.M. No. 03-03-03-SC
consolidating the commercial Securities and Exchange Commission
(SEC) courts and the intellectual property courts in one (1) Regional
Trial Court (RTC) branch in a particular locality, i.e., the Special
Commercial Court, to streamline the court structure and to promote
expediency.
 The erroneous raffling to a regular branch instead of to a Special
Commercial Court is only a matter of procedure — that is, an incident
related to the exercise of jurisdiction — and, thus, should not negate
the jurisdiction which the Regional Trial Court (RTC) of Muntinlupa City
had already acquired. In such a scenario, the proper course of action
was not for the commercial case to be dismissed; instead, Branch 276
should have first referred the case to the Executive Judge for re-
docketing as a commercial case; thereafter, the Executive Judge
should then assign said case to the only designated Special
Commercial Court in the station, i.e., Branch 256.
 If the Regional Trial Court (RTC) acquiring jurisdiction has no branch
designated as a Special Commercial Court, then it should refer the
case to the nearest RTC with a designated Special Commercial Court
branch within the judicial region.
 The designation of Special Commercial Courts was merely intended
as a procedural tool to expedite the resolution of commercial cases in
line with the court’s exercise of jurisdiction.
 The petition is meritorious.
 At the outset, the Court finds Branch 276 to have correctly
categorized Civil Case No. 11-077 as a commercial case, 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 therelationship test and the nature of the controversy test,
the suit between the parties is clearly rooted in the existence of an
intra-corporate relationship and pertains to the enforcement of their
7
 before the RTC of Muntinlupa City seeking to enjoin the
sale of S.J. Land, Inc.’s shares which they purportedly
bought from S.J. Global, Inc.
 Essentially, petitioners alleged that the subscriptions for
the said shares were already paid by them in full in the
books of S.J. Land, Inc., but were nonetheless offered for
sale on July 29, 2011 to the corporation’s stockholders,
hence, their plea for injunction.
 The case was docketed as Civil Case No. 11-077 and
raffled to Branch 276, which is not a Special Commercial
Court.
 On August 9, 2011, said branch issued a temporary
restraining order, and later, granted the application for a
writ of preliminary injunction.
 After filing their respective answers to the complaint,
respondents filed a motion to dismiss on the ground
of lack of jurisdiction over the subject matter, pointing
out that the case involves an intra-corporate disputeand
should, thus, be heard by the designated Special
Commercial Court of Muntinlupa City.
In an Order, Branch 276 granted the motion to dismiss filed
by respondents. It found that the case involves an intra-
corporate dispute that is within the original and exclusive
jurisdiction of the RTCs designated as Special Commercial
Courts.
 It pointed out that the RTC of Muntinlupa City, Branch
256 (Branch 256) was specifically designated by the
Court as the Special Commercial Court, hence, Branch
276 had no jurisdiction over the case and cannot
lawfully exercise jurisdiction on the matter, including the
issuance of a Writ of Preliminary Injunction. Accordingly,
it dismissed the case.
 Dissatisfied, petitioners filed a motion for reconsideration,
arguing that they filed the case with the Office of the
Clerk of Court of the RTC of Muntinlupa City which
assigned the same to Branch 276 by raffle.
 As the raffle was beyond their control, they should not
be made to suffer the consequences of the wrong
assignment of the case
 They further maintained that the RTC has jurisdiction over
intra-corporate disputes under Republic Act No. (RA)
 8

correlative rights and obligations under the Corporation Code and 8799, but since the Court selected specific branches to
the internal and intra-corporate regulatory rules of the corporation, hear and decide such suits, the case must, at most, be
hence, intra-corporate, which should be heard by the designated transferred or raffled off to the proper branch.
Special Commercial Court as provided under A.M. No. 03-03-03-SC  In an Order, Branch 276 denied the motion for
dated June 17, 2003 in relation to Item 5.2, Section 5 of RA 8799. reconsideration, holding that it has no authority or power
 The present controversy lies, however, in the procedure to be to order the transfer of the case to the proper Special
followed when a commercial case — such as the instant intra- Commercial Court, citing Calleja v. Panday (Calleja);
corporate dispute — has been properly filed in the official station of hence, the present petition.
the designated Special Commercial Court but is, however, later
wrongly assigned by raffle to a regular branch of that station.
 As a basic premise, let it be emphasized that a court’s acquisition of
jurisdiction over a particular case’s subject matter is different from
incidents pertaining to the exercise of its jurisdiction.
 Jurisdiction over the subject matter of a case is conferred by law,
whereas a court’s exercise of jurisdiction, unless provided by the law
itself, is governed by the Rules of Court or by the orders issued from
time to time by the Court.
 In Lozada v. Bracewell, it was recently held that the matter of whether
the RTC resolves an issue in the exercise of its general jurisdiction or of
its limited jurisdiction as a special court is only a matter of procedure
and has nothing to do with the question of jurisdiction.
 Pertinent to this case is RA 8799 which took effect on August 8, 2000.
By virtue of said law, jurisdiction over cases enumerated in Section 5
of Presidential Decree No. 902-A was transferred from the Securities
and Exchange Commission (SEC) to the RTCs, being courts of general
jurisdiction.
 The legal attribution of Regional Trial Courts as courts of general
jurisdiction stems from Section 19(6), Chapter II of Batas Pambansa
Bilang (BP) 129, known as “The Judiciary Reorganization Act of 1980”
 To clarify, the word “or” in Item 5.2, Section 5 of RA 8799 was
intentionally used by the legislature to particularize the fact that the
phrase “the Courts of general jurisdiction” is equivalent to the phrase
“the appropriate Regional Trial Court.” In other words, the jurisdiction
of the SEC over the cases enumerated under Section 5 of PD 902-A
was transferred to the courts of general jurisdiction, that is to say (or,
otherwise known as), the proper Regional Trial Courts.
 Therefore, one must be disabused of the notion that the transfer of
jurisdiction was made only in favor of particular RTC branches, and
not the RTCs in general.
 Consistent with the foregoing, history depicts that when the transfer of
SEC cases to the RTCs was first implemented, they were transmitted to
the Executive Judges of the RTCs for raffle between or among its
 9

different branches, unless a specific branch has been designated as

a Special Commercial Court, in which instance, the cases
were transmitted to said branch.
 It was only on November 21, 2000 that the Court designated certain
RTC branches to try and decide said SEC cases without, however,
providing for the transfer of the cases already distributed to or filed
with the regular branches thereof. Thus, on January 23, 2001, the
Court issued SC Administrative Circular No. 08-2001 directing the
transfer of said cases to the designated courts (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 one RTC branch in a particular locality
 Accordingly, the RTC branch so designated was mandated to try and
decide SEC cases, as well as those involving violations of intellectual
property rights, which were, thereupon, required to be filed in the
Office of the Clerk of Court in the official station of the designated
Special Commercial Courts
 It is important to mention that the Court’s designation of Special
Commercial Courts was made in line with its constitutional authority to
supervise the administration of all courts as provided under Section 6,
Article VIII of the 1987 Constitution
 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 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
removed, given that the power to define, prescribe, and apportion
jurisdiction is, as a general rule, a matter of legislative prerogative.
 Here, petitioners filed a commercial case, i.e., an intra-corporate
dispute, with the Office of the Clerk of Court in the RTC of Muntinlupa
City, which is the official station of the designated Special
Commercial Court, in accordance with A.M. No. 03-03-03-SC. It is,
therefore, from the time of such filing that the RTC of Muntinlupa City
acquired jurisdiction over the subject matter or the nature of the
action.
 Unfortunately, the commercial case was wrongly raffled to a regular
branch, i.e., Branch 276, instead of being assigned to the sole Special
Commercial Court in the RTC of Muntinlupa City, which is Branch 256.
This error may have been caused by a reliance on the complaint’s
caption, i.e., “Civil Case for Injunction with prayer for Status
Quo Order, TRO and Damages,” which, however, contradicts and
 10

more importantly, cannot prevail over its actual allegations that

clearly make out an intra-corporate dispute
 According to jurisprudence, “it is not the caption but the allegations in
the complaint or other initiatory pleading which give meaning to the
pleading and on the basis of which such pleading may be legally
characterized.”
 However, so as to avert any future confusion, the Court requires
henceforth, that all initiatory pleadings state the action’s nature both
in its caption and the body, which parameters are defined in the
dispositive portion of this Decision.
 Going back to the case at bar, the Court nonetheless deems that the
erroneous raffling to a regular branch instead of to a Special
Commercial Court is only a matter of procedure — that is, an incident
related to the exercise of jurisdiction — and, thus, should not negate
the jurisdiction which the RTC of Muntinlupa City had already
acquired.
 In such a scenario, the proper course of action was not for the
commercial case to be dismissed; instead, Branch 276 should have
first referred the case to the Executive Judge for re-docketing as
a commercial case; thereafter, the Executive Judge should then
assign said case to the only designated Special Commercial Court in
the station, i.e., Branch 256.
 Note that the procedure would be different where the RTC acquiring
jurisdiction over the case has multiple special commercial court
branches; in such a scenario, the Executive Judge, after re-docketing
the same as a commercial case, should proceed to order its re-
raffling among the said special branches.
 Meanwhile, if the RTC acquiring jurisdiction has no branch designated
as a Special Commercial Court, then it should refer the case to the
nearest RTC with a designated Special Commercial Court branch
within the judicial region.
 Upon referral, the RTC to which the case was referred to should re-
docket the case as a commercial case, and then: (a) if the said RTC
has only one branch designated as a Special Commercial Court,
assign the case to the sole special branch; or (b) if the said RTC has
multiple branches designated as Special Commercial Courts, raffle off
the case among those special branches.
 In all the above mentioned scenarios, any difference regarding the
applicable docket fees should be duly accounted for. On the other
hand, all docket fees already paid shall be duly credited, and any
excess, refunded.
 At this juncture, the Court finds it fitting to clarify that the RTC

mistakenly relied on the Calleja case to support its ruling. In Calleja,
an intra-corporate dispute among officers of a private corporation
with principal address at Goa, Camarines Sur, was filed with the RTC
of San Jose, Camarines Sur, Branch 58 instead of the RTC of Naga
City, which is the official station of the designated Special
Commercial Court for Camarines Sur. Consequently, the Court set
aside the RTC of San Jose, Camarines Sur’s order to transfer the case
to the RTC of Naga City and dismissed the complaint considering that
it was filed before a court which, having no internal branch
designated as a Special Commercial Court, had no jurisdiction over
those kinds of actions, i.e., intra-corporate disputes. Calleja involved
two different RTCs, i.e., the RTC of San Jose, Camarines Sur and the
RTC of Naga City, whereas the instant case only involves one RTC, i.e.,
the RTC of Muntinlupa City, albeit involving two different branches of
the same court, i.e., Branches 256 and 276. Hence, owing to the
variance in the facts attending, it was then improper for the RTC to
rely on the Calleja ruling.
 Harkening back to the statute that had conferred subject matter
jurisdiction, two things are apparently clear: (a) that the SEC’s subject
matter jurisdiction over intra-corporate cases under Section 5 of
Presidential Decree No. 902-A was transferred to the Courts of general
jurisdiction, i.e., the appropriate Regional Trial Courts; and (b) the
designated branches of the Regional Trial Court, as per the rules
promulgated by the Supreme Court, shall exercise jurisdiction over
such cases.
 Similarly, the transfer of the present intra-corporate dispute from
Branch 276 to Branch 256 of the same RTC of Muntinlupa City, subject
to the parameters above discussed is proper and will further the
purposes stated in A.M. No. 03-03-03-SC of attaining a speedy and
efficient administration of justice.
 court procedure.
11
 For further guidance, the Court finds it apt to point out
that the same principles apply to the inverse situation of
ordinary civil cases filed before the proper RTCs but
wrongly raffled to its branches designated as Special
Commercial Courts.
 In such a scenario, the ordinary civil case should then be
referred to the Executive Judge for re-docketing as an
ordinary civil case; thereafter, the Executive Judge
should then order the raffling of the case to all
branches of the same RTC, subject to limitations under
existing internal rules, and the payment of the correct
docket fees in case of any difference.
 To restate, the designation of Special Commercial Courts
was merely intended as a procedural tool to expedite
the resolution of commercial cases in line with the
court’s exercise of jurisdiction. This designation was not
made by statute but only by an internal Supreme Court
rule under its authority to promulgate rules governing
matters of procedure and its constitutional mandate to
supervise the administration of all courts and the
personnel thereof.
 Certainly, an internal rule promulgated by the Court
cannot go beyond the commanding statute. But as a
more fundamental reason, the designation of Special
Commercial Courts is, to stress, merely an incident
related to the court’s exercise of jurisdiction, which, as
first discussed, is distinct from the concept of jurisdiction
over the subject matter.
 The RTC’s general jurisdiction over ordinary civil cases is
therefore not abdicated by an internal rule streamlining