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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.
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