Cases about Court Jurisdiction part 2

Hilario vs. Salvador (GR 160384)

The jurisdiction of the court over an action involving title to or possession of land is now determined by the assessed value of the said property and not the market value thereof. The assessed value of real property is the fair market value of the real property multiplied by the assessment level. It is synonymous to taxable value. The fair market value is the price at which a property may be sold by a seller, who is not compelled to sell, and bought by a buyer, who is not compelled to buy.

Heirs of Sps Teofilo and Elisa Reterta vs. Sps. Lorenzo More and Virginia Lopez (GR 159941)

The original and exclusive jurisdiction over a complaint for quieting of title and reconveyance involving friar land belongs to either the Regional Trial Court (RTC) or the Municipal Trial Court (MTC). Hence, the dismissal of such a complaint on the ground of lack of jurisdiction due to the land in litis being friar land under the exclusive jurisdiction of the Land Management Bureau (LMB) amounts to manifest grave abuse of discretion that can be corrected through certiorari.

Radio communications of the Phils. vs CA (GR 136109)

It is settled that a breach of contract is a cause of action either for specific performance or rescission of contracts. In Manufacturers Distributors, Inc. v. Siu Liong, the Court held that actions for specific performance are incapable of pecuniary estimation and therefore fall under the jurisdiction of the Regional Trial Court. Here, the averments in the complaint reveal that the suit filed by private respondent was primarily one for specific performance as it was aimed to enforce their three-year lease contract which would incidentally entitle him to monetary awards if the court should find that the subject contract of lease was breached. As alleged therein, petitioners failure to pay rentals due for the period from January to March 1997, constituted a violation of their contract which had the effect of accelerating the payment of monthly rentals for the years 1997 and 1998.

The same complaint likewise implied a premature and unilateral termination of the term of the lease with the closure of and removal all communication equipment in the leased premises. Under the circumstances, the court has to scrutinize the facts and the applicable laws in order to determine whether there was indeed a violation of their lease agreement that would justify the award of rentals and damages. The prayer, therefore, for the payment of unpaid rentals in the amount of P84,000.00 plus damages consequent to the breach is merely incidental to the main action for specific performance.

Mendoza vs. Teh (GR 122646)

An action for reconveyance, which involves title title to property worth millions of pesos, such as the lots subject of this case, is cognizable by the RTC. Likewise falling within its jurisdiction are actions incapable of pecuniary estimation, such as the appointment of an administratrix for an estate. Even the Rules on venue of estate proceedings (Section 1 of Rule 73) impliedly recognizes the jurisdiction of the RTC over petitions for granting of letters of administration.

On the other hand, probate proceedings for the settlement of estate are within the ambit of either the RTC or MTC depending on the net worth of the estate. By arguing that the allegation seeking such appointment as administratrix ousted the RTC of its jurisdiction, both public and private respondents confuses jurisdiction with venue. Section 2 of Rule 4 as revised by Circular 13-95 provides that actions involving title to property shall be tried in the province where the property is located, in this case, – Batangas. The mere fact that petitioners deceased husband resides in Quezon City at the time of his death affects only the venue but not the jurisdiction of the Court.

Irene Sante and Reynaldo Sante vs. Hon. Judge Clavarall GR 173915)

In the instant case, the complaint filed in Civil Case No. 5794-R is for the recovery of damages for the alleged malicious acts of petitioners. The complaint principally sought an award of moral and exemplary damages, as well as attorneys fees and litigation expenses, for the alleged shame and injury suffered by respondent by reason of petitioners utterance while they were at a police station in Pangasinan. It is settled that jurisdiction is conferred by law based on the facts alleged in the complaint since the latter comprises a concise statement of the ultimate facts constituting the plaintiffs causes of action. It is clear, based on the allegations of the complaint, that respondents main action is for damages. Hence, the other forms of damages being claimed by respondent, e.g., exemplary damages, attorneys 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.

In Mendoza v. Soriano, it was held that 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. In the said case, the respondents claim of P929,000.06 in damages and P25,000 attorneys fees plus P500 per court appearance was held to represent the monetary equivalent for compensation of the alleged injury. The Court therein held that the total amount of monetary claims including the claims for damages was the basis to determine the jurisdictional amount.

Office of the Ombudsman vs. Rodriguez (GR 172700)

The facts in the present case are analogous to those in Laxina, Sr. v. Ombudsman, which likewise involved identical administrative complaints filed in both the Ombudsman and the sangguniang panlungsod against a punong barangay for grave misconduct. The Court held therein that the rule against forum shopping applied only to judicial cases or proceedings, not to administrative cases. Thus, even if complainants filed in the Ombudsman and the sangguniang bayan identical complaints against private respondent, they did not violate the rule against forum shopping because their complaint was in the nature of an administrative case.

In administrative cases involving the concurrent jurisdiction of two or more disciplining authorities, the body in which the complaint is filed first, and which opts to take cognizance of the case, acquires jurisdiction to the exclusion of other tribunals exercising concurrent jurisdiction. In this case, since the complaint was filed first in the Ombudsman, and the Ombudsman opted to assume jurisdiction over the complaint, the Ombudsmans exercise of jurisdiction is to the exclusion of the sangguniang bayan exercising concurrent jurisdiction.

It is a hornbook rule that jurisdiction is a matter of law. Jurisdiction, once acquired, is not lost upon the instance of the parties but continues until the case is terminated. When herein complainants first filed the complaint in the Ombudsman, jurisdiction was already vested on the latter. Jurisdiction could no longer be transferred to the sangguniang bayan by virtue of a subsequent complaint filed by the same complainants.

Union Bank of the Phils. vs. PP (GR 192565)

The case presents to us the issue of what the proper venue of perjury under Article 183 of the RPC should be Makati City, where the Certificate against Forum Shopping was notarized, or Pasay City, where the Certification was presented to the trial court.

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We hold that our ruling in Sy Tiong is more in accord with Article 183 of the RPC and Section 15(a), Rule 110 of the 2000 Revised Rules of Criminal Procedure. To reiterate for the guidance of the Bar and the Bench, the crime of perjury committed through the making of a false affidavit under Article 183 of the RPC is committed at the time the affiant subscribes and swears to his or her affidavit since it is at that time that all the elements of the crime of perjury are executed. When the crime is committed through false testimony under oath in a proceeding that is neither criminal nor civil, venue is at the place where the testimony under oath is given.

If in lieu of or as supplement to the actual testimony made in a proceeding that is neither criminal nor civil, a written sworn statement is submitted, venue may either be at the place where the sworn statement is submitted or where the oath was taken as the taking of the oath and the submission are both material ingredients of the crime committed. In all cases, determination of venue shall be based on the acts alleged in the Information to be constitutive of the crime committed.

Organo vs. Sandiganbayan (GR 136916)

Does the Respondent Court, the Honorable Sandiganbayan, have jurisdiction over a case of plunder when none of the accused occupy Salary Grade 27 or higher as provided under Republic Act No. 6758 ?

The Sandiganbayans jurisdiction over petitioners mother and the other accused in Criminal Case No. 24100 has been resolved by the Supreme Court in Lilia B. Organo v. Sandiganbayan. In that case, we ruled that the Sandiganbayan has no jurisdiction over the crime of plunder unless committed by public officials and employees occupying the positions with Salary Grade 27 or higher, under the Compensation and Position Classification Act of 1989 (Republic Act No. 6758) in relation to their office.The Court explained that the crime of plunder defined in Republic Act No. 7080, as amended by Republic Act No. 7659, was provisionally placed within the jurisdiction of the Sandiganbayan until otherwise provided by law. Republic Act No. 8249, enacted on February 5, 1997, is the special law that provided for the jurisdiction of the Sandiganbayan otherwise than that prescribed in Republic Act No. 7080.

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The apparent intendment of these amendments is to ease the dockets of the Sandiganbayan and to allow the Anti-Graft Court to focus its efforts on the trial of those occupying higher positions in government, the proverbial big fish. Section 4, as amended, freed the Sandiganbayan from the task of trying cases involving lower-raking government officials, imposing such duty upon the regular courts instead. The present structure is also intended to benefit these officials of lower rank, especially those residing outside Metro Manila, charged with crimes related to their office, who can ill-afford the expenses of a trial in Metro Manila.

Ronilo Sorreda vs. Cambridge Electronics corp (GR172927)

This case rests on the issue of whether the labor arbiter had the jurisdiction.

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A labor arbiter may only take cognizance of a case and award damages where the claim for such damages arises out of an employer-employee relationship.

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While there was an employer-employee relationship between the parties under their five-month per-project contract of employment, the present dispute is neither rooted in the aforestated contract nor is it one inherently linked to it. Petitioner insists on a right to be employed again in respondent company and seeks a determination of the existence of a new and separate contract that established that right. As such, his case is within the jurisdiction not of the labor arbiter but of the regular courts. The NLRC and the CA were therefore correct in ruling that the labor arbiter erroneously took cognizance of the case.

Miranda vs. Tuliao (GR 158763)

Our pronouncement in Santiago shows a distinction between custody of the law and jurisdiction over the person. Custody of the law is required before the court can act upon the application for bail, but is not required for the adjudication of other reliefs sought by the defendant where the mere application therefor constitutes a waiver of the defense of lack of jurisdiction over the person of the accused.  Custody of the law is accomplished either by arrest or voluntary surrender, while jurisdiction over the person of the accused is acquired upon his arrest or voluntary appearance. One can be under the custody of the law but not yet subject to the jurisdiction of the court over his person, such as when a person arrested by virtue of a warrant files a motion before arraignment to quash the warrant. On the other hand, one can be subject to the jurisdiction of the court over his person, and yet not be in the custody of the law, such as when an accused escapes custody after his trial has commenced.  Being in the custody of the law signifies restraint on the person, who is thereby deprived of his own will and liberty, binding him to become obedient to the will of the law. Custody of the law is literally custody over the body of the accused. It includes, but is not limited to, detention.

 

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Cases about Court Jurisdiction part 1

Victorino Quinagoran vs. CA (GR 155179)

The question posed in the present petition is not complicated, i.e., does the RTC have jurisdiction over all cases of recovery of possession regardless of the value of the property involved?

The answer is no. The doctrine on which the RTC anchored its denial of petitioner’s Motion to Dismiss, as affirmed by the CA — that all cases of recovery of possession or accion publiciana lies with the regional trial courts regardless of the value of the property — no longer holds true. As things now stand, a distinction must be made between those properties the assessed value of which is below P20,000.00, if outside Metro Manila; and P50,000.00, if within.

Republic Act No. 7691 which amended Batas Pambansa Blg. 129 and which was already in effect when respondents filed their complaint with the RTC on October 27, 1994, expressly provides:

SEC. 19. Jurisdiction in civil cases Regional Trial Courts shall exercise exclusive original jurisdiction:

x x x x

(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 Twenty thousand pesos (P20,000.00) or, for civil actions in Metro Manila, where such value exceeds Fifty thousand pesos (P50,000.00) except for forcible entry into and unlawful detainer of lands or buildings, original jurisdiction over which is conferred upon the Metropolitan Trial Courts, Municipal Trial Courts, and Municipal Circuit Trial Courts.

x x x x

SEC. 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:

x x x x

(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 or whatever kind, attorney’s fees, litigation expenses and costs:Provided That in cases of land not declared for taxation purposes, the value of such property shall be determined by the assessed value of the adjacent lots.

Jurisdiction of the court does not depend upon the answer of the defendant or even upon agreement, waiver or acquiescence of the parties.Indeed, the jurisdiction of the court over the nature of the action and the subject matter thereof cannot be made to depend upon the defenses set up in the court or upon a motion to dismiss for, otherwise, the question of jurisdiction would depend almost entirely on the defendant.

Considering that the respondents failed to allege in their complaint the assessed value of the subject property, the RTC seriously erred in denying the motion to dismiss. Consequently, all proceedings in the RTC are null and void, and the CA erred in affirming the RTC.

Cervantes vs. PP (GR 147406)

The general rule should, however, be, as it has always been, that the issue of jurisdiction may be raised at any stage of the proceedings, even on appeal, and is not lost by waiver or by estoppel.Estoppel by laches, to bar a litigant from asserting the courts absence or lack of jurisdiction, only supervenes in exceptional cases similar to the factual milieu of Tijam v. Sibonghanoy. Indeed, the fact that a person attempts to invoke unauthorized jurisdiction of a court does not estop him from thereafter challenging its jurisdiction over the subject matter, since such jurisdiction must arise by law and not by mere consent of the parties. This is especially true where the person seeking to invoke unauthorized jurisdiction of the court does not thereby secure any advantage or the adverse party does not suffer any harm.

Applying the said doctrine to the instant case, the petitioner is in no way estopped by laches in assailing the jurisdiction of the RTC, considering that he raised the lack thereof in his appeal before the appellate court. At that time, no considerable period had yet elapsed for laches to attach. True, delay alone, though unreasonable, will not sustain the defense of estoppel by laches unless it further appears that the party, knowing his rights, has not sought to enforce them until the condition of the party pleading laches has in good faith become so changed that he cannot be restored to his former state, if the rights be then enforced, due to loss of evidence, change of title, intervention of equities, and other causes.

Sps. Flores-Cruz vs. Sps Goli-Cruz (GR 172217)

It is axiomatic that the nature of the action on which depends the question of whether a suit is within the jurisdiction of the court is determined solely by the allegations in the complaint and the law at the time the action was commenced. Only facts alleged in the complaint can be the basis for determining the nature of the action and the courts competence to take cognizance of it.  One cannot advert to anything not set forth in the complaint, such as evidence adduced at the trial, to determine the nature of the action thereby initiated.

Manotoc vs. CA (GR 130974)

The courts jurisdiction over a defendant is founded on a valid service of summons. Without a valid service, the court cannot acquire jurisdiction over the defendant, unless the defendant voluntarily submits to it. The defendant must be properly apprised of a pending action against him and assured of the opportunity to present his defenses to the suit. Proper service of summons is used to protect ones right to due process.

PP vs. CA (GR 154557)

Where a court acquired jurisdiction over an action, its jurisdiction continues to the final conclusion of the case. Such jurisdiction is not affected by new legislation placing jurisdiction over such dispute in another court or tribunal unless the statute provides for retroactivity.

It is quite glaring from Sec. 7 of RA 7691 that said law has limited retroactivity only to civil cases. As such, the CA indeed committed grave abuse of discretion as it acted in an arbitrary and patently erroneous exercise of judgment equivalent to lack of jurisdiction. Hence, the use of Rule 65 is proper.

RP vs Bantigue Point Development Corp (GR 162322)

At the outset, we rule that petitioner Republic is not estopped from questioning the jurisdiction of the lower court, even if the former raised the jurisdictional question only on appeal. The rule is settled that lack of jurisdiction over the subject matter may be raised at any stage of the proceedings. Jurisdiction over the subject matter is conferred only by the Constitution or the law. It cannot be acquired through a waiver or enlarged by the omission of the parties or conferred by the acquiescence of the court. Consequently, questions of jurisdiction may be cognizable even if raised for the first time on appeal.

The ruling of the Court of Appeals that a party may be estopped from raising such [jurisdictional] question if he has actively taken part in the very proceeding which he questions, belatedly objecting to the courts jurisdiction in the event that the judgment or order subsequently rendered is adverse to him is based on the doctrine of estoppel by laches. We are aware of that doctrine first enunciated by this Court inTijam v. Sibonghanoy. In Tijam, the party-litigant actively participated in the proceedings before the lower court and filed pleadings therein. Only 15 years thereafter, and after receiving an adverse Decision on the merits from the appellate court, did the party-litigant question the lower courts jurisdiction. Considering the unique facts in that case, we held that estoppel by laches had already precluded the party-litigant from raising the question of lack of jurisdiction on appeal. In Figueroa v. People, we cautioned that Tijam must be construed as an exception to the general rule and applied only in the most exceptional cases whose factual milieu is similar to that in the latter case.

The facts are starkly different in this case, making the exceptional rule in Tijam inapplicable. Here, petitioner Republic filed its Opposition to the application for registration when the records were still with the RTC. At that point, petitioner could not have questioned the delegated jurisdiction of the MTC, simply because the case was not yet with that court. When the records were transferred to the MTC, petitioner neither filed pleadings nor requested affirmative relief from that court. On appeal, petitioner immediately raised the jurisdictional question in its Brief. Clearly, the exceptional doctrine of estoppel by laches is inapplicable to the instant appeal.

Laches has been defined as the failure or neglect, for an unreasonable and unexplained length of time, to do that which, by exercising due diligence, could or should have been done earlier; it is negligence or omission to assert a right within a reasonable time, warranting the presumption that the party entitled to assert it either has abandoned or declined to assert it. In this case, petitioner Republic has not displayed such unreasonable failure or neglect that would lead us to conclude that it has abandoned or declined to assert its right to question the lower court’s jurisdiction.

Katon vs. Palanca (GR 151149)

Where prescription, lack of jurisdiction or failure to state a cause of action clearly appear from the complaint filed with the trial court, the action may be dismissed motu proprio by the Court of Appeals, even if the case has been elevated for review on different grounds. Verily, the dismissal of such cases appropriately ends useless litigations.

Ortigas and Co. vs. CA (GR 129822)

The sole issue in this case is whether or not the CA erred in affirming the lower courts ruling that jurisdiction over the City’s action lies with the RTC, not with the HLURB.

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Ortigas maintains that the HLURB has jurisdiction over the complaint since a land developer’s failure to comply with its statutory obligation to provide open spaces constitutes unsound real estate business practice that Presidential Decree (P.D.) 1344 prohibits. Executive Order 648 empowers the HLURB to hear and decide claims of unsound real estate business practices against land developers.

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Obviously, the City had not bought a lot in the subject area from Ortigas which would give it a right to seek HLURB intervention in enforcing a local ordinance that regulates the use of private land within its jurisdiction in the interest of the general welfare. It has the right to bring such kind of action but only before a court of general jurisdiction such as the RTC.