1) SANTE v.
CLARAVALL
Doctrine:
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 ultimate facts constituting plaintiffs cause
of action.
FACTS:
Respondent Vita Kalashian filed before RTC Baguio a complaint for damages against
petitioners Irene and Reynaldo Sante.
Vita alleged that:
 while she was inside the Police Station in, Irene asked her how many rounds of
sex she had with her boss, Bert (Vita’s friend and body guard who is a suspect of
killing petitoners’ close relative), and cursed her in the presence of other persons
and police officers
 Petitioners Sante went around the area telling people that she is protecting and
cuddling the suspects in the aforesaid killing
Petitioners Sante filed a MTD on the ground that it was the Municipal Trial Court in Cities
and not RTC of Baguio that had jurisdiction over the case
 arguing that the amount of claim for moral damages was not more than the
jurisdictional amount of P300k, because the claim for exemplary damages should be
excluded in computing the total claim
The trial court DENIED the MTD and held that the total claim of respondent Vita amounted
to P420k which was above the jurisdictional amount for MTCC’s outside Metro Manila.
Petitioners Sante, after their MR was dismissed, filed a Petition for Certiorari and
Prohibition (FIRST) before CA.
Meanwhile, Vita and her husband filed an Amended Complaint increasing the claim for
moral damages from P300k to P1M.
Petitioners Sante filed a MTD  DENIED
Petitioners Sante again filed a Petition for Certiorari and Prohibition (SECOND) before CA
claiming that the trial court committed grave abuse of discretion in allowing the
amendment of the complaint to increase amount of damages
The CA GRANTED the FIRST petition for certiorari and prohibition, annulling the orders to
pay damages for lack of jurisdiction  held that:
 the case clearly falls under the jurisdiction of MTCC since Vita was seeking to
recover P300k for moral damages
 the totality of claim rule used for determining which court had jurisdiction could
not be applied to the case because Vita’s claim for exemplary damages was not a
separate and distinct cause of action from her claim of moral damages, but
merely incidental
The CA then AFFIRMED RTC’s decision in denying the MTD, in the SECOND petition filed by
petitioners Sante  held that:
 the total amount demanded in the complaint constitutes the basis of jurisdiction
and did not find merit in petitioners Sante’s argument that the claims for
exemplary damages and atty’s fees are mere incidental and should not be
included in total claim
 Vita can amend her complaint in increasing amount of damages on the ground
that the trial court has jurisdiction over the original complaint
ISSUE: WON the RTC acquired jurisdiction over the case- YES
RULING:
-Administrative Circular No. 09-94: where the claim of 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 present case, the complaint filed by Vita is for the recovery of damages for alleged
malicious acts of petitioners Sante  sought the award of moral and exemplary damages,
atty’s fees, and litigation expenses for the alleged shame and injury suffered by Vita
-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 ultimate facts constituting plaintiffs cause
of action
-Clearly, based on the allegations of Vita’s complaint, the main action is for damages 
hence, other forms of damages being claimed by respondent (exemplary, atty’s fees,
litigation expense) are not merely incidental to or consequence of main action but
constitute primary relief prayed for in the complaint
-Considering that the total amount for damages claimed is P420k, the CA was correct in
ruling that RTC had jurisdiction over the case
WHEREFORE, petition is DENIED.
Winner: Respondent Vita Kalashian
2) MICHAEL SEBASTIAN, Petitioner, v. ANNABEL LAGMAY NG, REPRESENTED BY HER
ATTORNEY-IN-FACT, ANGELITA LAGMAY, Respondent.
DECISION
BRION, J.:
We resolve the petition for review on certiorari,1 filed by petitioner Michael Sebastian
(Michael), assailing the March 31, 2004 Decision,2 and the July 15, 2004 Resolution3 of the
Court of Appeals (CA) in CA-G.R. SP No. 65450.

The CA decision reversed and set aside the decision of the Regional Trial Court (RTC) of
Palayan City, Branch 40, in SP. Proc. Case No. 0096-P.
Factual Background
Sometime in 1997, Angelita Lagmay (Angelita), acting as representative and attorney-in-fact
of her daughter Annabel Lagmay Ng (Annabel), filed a complaint before
the 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 financial resources to
buy a truck. She alleged that while Annabel was working in Hongkong, Annabel sent
Michael 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.
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. The kasunduan was signed by Angelita (on behalf of
Annabel), Michael, and the members of the pangkat ng tagapagkasundo.
The kasunduan reads:
KASUNDUAN
Nagkasundo ang dalawang panig na pagkayari ng labing apat na buwan (14 months) Simula
ngayong July 9, 1997 hanggang September 1998 ay kailangan ng maibigay ni Mr. Sebastian
ang pera ni Ms. Anabelle Lagmay.
At napagkasunduan ay dalawang hulog ang halagang P250,000.00 na pera ni Ms.Lagmay at
Simula ng pagbibigay ni Mr. Sebastian ay sa buwan ng September 1998.
At upang may katunayan ang lahat ng napag usapan ay lumagda sa ibaba nito at sa harap ng
mga saksi ngayong ika-9 ng Hulyo, 1997
Mrs. Angelita Lagmay - (Lagda)
Mr. Michael Sebastian - (Lagda)
Saksi: Kagawad Rolando Mendizabal - (Lagda)
Hepe Quirino Sapon - (Lagda)
Benjamin Sebastian - (Lagda)
Jun Roxas - (Lagda)
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 of 1991 [Republic Act (R.A.) No. 7160], and Section 14 of its
Implementing Rules. When Michael failed to honor the kasunduan, Angelita brought the
matter back to the Barangay, but the BarangayCaptain 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) of Laur and
Gabaldon, Nueva Ecija, a Motion for Execution of the kasunduan.
Michael moved for the dismissal of the Motion for Execution, citing as a ground Angelita's
alleged violation of Section 15, Rule 13 of the 1997 Rules of Civil Procedure.
On January 17, 2000, the MCTC rendered a decision5 in favor of Annabel, the dispositive
portion of which reads, as follows:
WHEREFORE, the plaintiff through counsel has satisfactorily proven by preponderance of
evidence based on Exhibits "A," "B," "C," "D," and "F," that defendant has obligation to the
plaintiff in the amount ofP250,000.00.
IN VIEW OF THE FOREGOING, the Motion for Execution filed by the plaintiff is hereby
granted based on Sec. 2, Rule 7 of the Implementing Rules and Regulations of Republic Act
No. 7160, and therefore, defendant is hereby ordered within 15 days upon receipt of this
decision to pay the plaintiff the amount of P250,000.00 as evidenced by the Kasunduan
(Exhibit "C") with legal interests from July 9, 1997 until said obligation is fully paid, and to
pay attorney's fees for the plaintiffs counsel in the amount of P15,000.00 and to pay the
cost of the suit.
SO ORDERED.
Michael filed an appeal with the RTC arguing that the MCTC committed grave abuse of
discretion in prematurely deciding the case. Michael also pointed out that a hearing was
necessary for the petitioner to establish the genuineness and due execution of
the kasunduan.
The Regional Trial Court's Ruling
In its November 13, 2000 Decision,6 the RTC, Branch 40 of Palayan City upheld the MCTC
decision, finding Michael liable to pay Annabel the sum of P250,000.00. It held that Michael
failed to assail the validity of the kasunduan, or to adduce any evidence to dispute
Annabel's claims or the applicability of the Implementing Rules and Regulations of R.A. No.
7160. The dispositive portion of the decision reads:
WHEREFORE, the assailed Decision and Order of the lower court is hereby MODIFIED in that
the appellant is ordered to pay the appellee the amount of Two hundred Fifty Thousand
pesos (P250,000.00) plus twelve percent interest(12%) per annum from September, 1998
up to the time it is actually paid and fifty Thousand Pesos(P50,000.00) representing
attorney's fees.
Michael filed a Motion for Reconsideration arguing that: (i) an amicable settlement or
arbitration award can be enforced by the Lupon within six (6) months from date of
settlement or after the lapse of six (6) months, by ordinary civil action in the appropriate (1) there was no record of the complaint in the Barangay;
City or Municipal Trial Court and not by a mere Motion for execution; and (ii) the MCTC (2) there was no notice of mediation sent to him;
does not have jurisdiction over the case since the amount of P250,000.00 (as the subject (3) there was no constitution of the Pangkat Ng Tagapagasundo;
matter of the kasunduan) is in excess of MCTC's jurisdictional amount of P200,000.00.7 (4) the parties were never called upon to choose the three (3) members from
among the Luponmembers;
In its March 13, 2001 Order, the RTC granted Michael's Motion for Reconsideration, and (5) he had no participation in the execution of the kasunduan;
ruled that there is merit in the jurisdictional issue he raised. It dismissed Angelita's Motion (6) his signature in the kasunduan was forged;
for Execution, and set aside the MCTC Decision. The dispositive portion of the said Order (7) he did not personally appear before the Barangay;
reads: (8) there was no attestation clause;
(9) the kasunduan was neither reported nor filed before the MCTC; and
WHEREFORE, the Motion for Reconsideration is GRANTED. The Decision of the Court dated (10) Annabel, the real party in interest, did not personally appear before
November 13, 2000 is hereby SET ASIDE. The Decision of the Municipal Trial Court of Laur, the Barangay as required by the law.
Nueva Ecija dated January 17, 2000 is likewise SET ASIDE and the Motion for Execution
of Kasunduan is DISMISSED, the said court having had no jurisdiction to hear and decide the Michael additionally claims that the kasunduan is merely in the nature of a private
matter.8 document. He also reiterates that since the amount of P250,000.00 - the subject matter of
the kasunduan - is in excess of MCTC's jurisdictional amount of P200,000.00,
the kasunduan is beyond the MCTC's jurisdiction to hear and to resolve. Accordingly, the
Angelita moved for the reconsideration of the March 13, 2001 Order, but the motion was
proceedings in the Barangay are all nullity.
subsequently denied. Aggrieved, she filed a Petition for Review9 with the CA.
The Issues
The Court of Appeal's Ruling
The issues to be resolved in the present petition are:
On August 2, 2001, the CA initially dismissed the petition for review on a mere technical
ground of failure to attach the Affidavit of Service. Angelita moved for reconsideration,
attaching in her motion the Affidavit of Service. The CA granted the motion. 1. Whether or not the MCTC has the authority and jurisdiction to execute
the kasunduan regardless of the amount involved;
On March 31, 2004, the CA rendered its decision granting the petition, and reversing the
RTC's decision. The CA declared that the "appropriate local trial court" stated in Section 2, 2. Whether or not the kasunduan could be given the force and effect of a final
Rule VII of the Implementing Rules of R.A. No. 7160 refers to the municipal trial courts. judgment; and
Thus, contrary to Michael's contention, the MCTC has jurisdiction to enforce any settlement
or arbitration award, regardless of the amount involved. 3. Whether or not the kasunduan can be enforced.

The CA also ruled that Michael's failure to repudiate the kasunduan in accordance with the
procedure prescribed under the Implementing Rules of R.A. No. 7160, rendered The Court's Ruling
the kasunduan final. Hence, Michael can no longer assail the kasunduan on the ground of
forgery.
We deny the petition.
Michael moved to reconsider this decision, but the CA denied his motion in its resolution
dated July 15, 2004. Hence, this petition. A perusal of the body of the motion for
execution shows that it is actually in the
The Petition nature of an action for execution; hence,
it was a proper remedy;
In the present petition for review on certiorari, Michael alleges that the kasunduan cannot
be given the force and effect of a final judgment because it did not conform to the We note at the outset that Michael raised - in his brief before the C A - the issue of wrong
provisions of the Katarungang Pambarangay law embodied in Book III, Title One, Chapter 7 remedy. He alleged that Angelita's recourse should have been to file a civil action, not a
of R.A. No. 7160. He points out the following irregularities in the kasunduan's, execution, mere motion for execution, in a regular court. However, the CA failed to address this issue
and claims that the agreement forged between him and Angelita was fictitious and and only ruled on the issues of thekasunduan's irregularities and the MCTC's jurisdiction.
simulated:
A simple reading of Section 417 of the Local Government Code readily discloses the two- It is well-settled that what are controlling in determining the nature of the pleading are the
tiered mode of enforcement of an amicable settlement. The provision reads: allegations in the body and not the caption.14

Section 417. Execution. - The amicable settlement or arbitration award may be enforced by Thus, the motion for execution that Angelita filed was intended to be an initiatory
execution by the lupon within six (6) months from the date of the settlement. After the pleading or an original action that is compliant with the requirement under Section 3,
lapse of such time, the settlement may be enforced by action in the appropriate city or Rule 6 of the Rules of Court that the complaint should allege the plaintiffs cause of action
municipal court. [Emphasis ours.] and the names and residences of the plaintiff and the defendant.

Angelita's motion could therefore be treated as an original action, and not merely as a
Under this provision, an amicable settlement or arbitration award that is not repudiated
motion/special proceeding. For this reason, Annabel has filed the proper remedy
within a period often (10) days from the settlement may be enforced by: first, execution by
prescribed under Section 417 of the Local Government Code.
the Lupon within six (6) months from the date of the settlement; or second, by an action in
the appropriate city or municipal trial court if more than six (6) months from the date of
However, Angelita should pay the proper docket fees corresponding to the filing of an
settlement has already elapsed.
action for execution. The docket fees shall be computed by the Clerk of Court of the MCTC,
with due consideration, of course, of what Angelita had already paid when her motion for
Under the first mode of enforcement, the execution of an amicable settlement could be
execution was docketed as a special proceeding.
done on mere motion of the party entitled thereto before the Punong Barangay.10 The
proceedings in this case are summary in nature and are governed by the Local Government
The kasunduan has the force and effect of a final judgment.
Code and the Katarungang PambarangayImplementing Rules and Regulations.
Under Section 416 of the Local Government Code, the amicable settlement and arbitration
The second mode of enforcement, on the other hand, is judicial in nature and could only be
award shall have the force and effect of a final judgment of a court upon the expiration
resorted to through the institution of an action in a regular form before the proper
often (10) days from the date of its execution, unless the settlement or award has been
City/Municipal Trial Court.11The proceedings shall be governed by the provisions of the
repudiated or a petition to nullify the award has been filed before the proper city or
Rules of Court.
municipal court.
Indisputably, Angelita chose to enforce the kasunduan under the second mode and filed a
Moreover, Section 14, Rule VI of the Katarungang Pambarangay Implementing Rules states
motion for execution, which was docketed as Special Proceedings No. 45-99. The question
that the party's failure to repudiate the settlement within the period often (10) days shall
for our resolution is:Whether the MCTC, through Angelita's motion for execution, is
be deemed a waiver of the right to challenge the settlement on the ground that his/her
expressly authorized to enforce the kasunduan under Section 417 of the Local Government
consent was vitiated by fraud, violence or intimidation.
Code?
In the present case, the records reveal that Michael never repudiated the kasunduan within
The Court rules in the affirmative.
the period prescribed by the law. Hence, the CA correctly ruled that the kasunduan has the
force and effect of a final judgment that is ripe for execution.
It is undisputed that what Angelita filed before the MCTC was captioned "motion for
execution," rather than a petition/complaint for execution.
Furthermore, the irregularities in the kasunduan's execution, and the claim of forgery are
deemed waived since Michael never raised these defenses in accordance with the
A perusal of the motion for execution, however, shows that it contains the material
procedure prescribed under the Local Government Code. Thus, we see no reason to discuss
requirements of an initiatory action.
these issues in the present case.
First, the motion is sufficient in form12 and substance.13 It is complete with allegations of
The MCTC has the authority and jurisdiction
the ultimate facts constituting the cause of action; the names and residences of the plaintiff
to enforce the kasunduan regardless of the amount involved.
and the defendant; it contains the prayer for the MCTC to order the execution of
the kasunduan; and there was also a verification and certification against forum shopping.
The Court also finds that the CA correctly upheld the MCTC's jurisdiction to enforce any
settlement or arbitration .award issued by the Lupon.
Furthermore, attached to the motion are: 1) the authenticated special power of attorney of
Annabel, authorizing Angelita to file the present action on her behalf; and 2) the copy of
We again draw attention to the provision of Section 417 of the Local Government Code that
the kasunduan whose contents were quoted in the body of the motion for execution.
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. 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.15
WHEREFORE, premises considered, we hereby DENY the petitioner's petition for review
on certiorari, and AFFIRM the March 31, 2004 Decision of the Court of Appeals in CA-G.R.
SP No. 65450.
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.
3) G.R. No. 176492, October 20, 2014,
MARIETTA N. BARRIDO, PETITIONER, VS. LEONARDO V. NONATO, RESPONDENT
Facts: Leonardo and Marrieta’s marriage was dissolved by reason of psychologyical
incapacity in 1996, hence Leonardo filed a complaint for partition over their property
consisting of a house and lot, since according to him, there was no more reason to maintain
their co-ownership. In her defense, Marrieta claimed that the property had been sold to
their children Joseph Raymond and Joseph Leo. She also moved for dismissal of the action
for lack of jurisdiction on the part of the MTCC Bacolod City, the action for partition being
an action incapable of pecuniary estimation. Per decision of the MTCC, it ruled in favour of
Marrietta and adjudicated the land to her, being the spouse with whom the majority of the
common children choose to remain. It also awarded moral damages in favour of Marrieta.
Leonardo appealed the ruling to the RTC, which reversed the MTCC ruling and ordered the
partition of the property, hence Marrieta appealed the RTC decision to the Court of Appeals
by petition for review. The appellate court denied Marietta’s appeal, ruling that since the
assessed value of the property is only P8,080.00, it clearly fell within the MTCC jurisdiction.
Though the RTC applied Art. 129 instead of Art. 147 thereof, it still correctly ordered the
partition of the property.
Marrieta elevated her case to the Supreme Court.
Held: The Supreme Court:
“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.
4) Brgy. San Roque, Talisay, Cebu vs Heirs of Franco Pastor
June 24, 2011
334 SCRA 127 – Political Law – Municipal Corporation – Eminent Domain – Expropriation –
BP 129
In 1997, Brgy. San Roque of Talisay, Cebu filed for an expropriation suit before the MTC of
Talisay against the heirs of Franco Pastor. The MTC denied the suit because apparently
under BP 129, MTCs do not have jurisdiction over expropriation cases as it is the RTCs that
are lodged with the power to try such cases. So Brgy. San Roque filed it before RTC Talisay
but then Judge Jose Soberano, Jr. denied the suit as he ruled that the 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. The judge
also concluded that the action should have been filed before the MTC since the value of the
subject property was less than P20,000.
ISSUE: Whether or not the RTC should take cognizance of the expropriation case.
HELD: Yes. 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; . . . . .” The present action involves the exercise of the right to
eminent domain, and that such right is incapable of pecuniary estimation.
What are the two phases of expropriation cases?
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. It ends with an order, if not of dismissal of the action, “of
condemnation declaring that the plaintiff has a lawful right to take the property sought to
be condemned, for the public use or purpose described in the complaint, upon the payment
of just compensation to be determined as of the date of the filing of the complaint.” An
order of dismissal, if this be ordained, would be a final one, of course, since it finally
disposes of the action and leaves nothing more to be done by the Court on the merits. So,
too, would an order of condemnation be a final one, for thereafter as the Rules expressly
state, in the proceedings before the Trial Court, “no objection to the exercise of the right of
condemnation (or the propriety thereof) shall be filed or heard.”
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.” This is done by
the Court with the assistance of not more than three (3) commissioners. The order fixing
the just compensation on the basis of the evidence before, and findings of, the
commissioners would be final, too. It would finally dispose of the second stage of the suit,
and leave nothing more to be done by the Court regarding the issue. . . .
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, 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.
5) Gonzales vs. GJH Land, Inc. (2015)
Summary Cases:
Subject: Nature of the case as an intra-corporate dispute; Jurisdiction vs. Exercise of
jurisdiction; RA 8799 vested jurisdiction in the RTC as courts of general jurisdiction;
Designation of certain RTCs as Special Commercial Courts is an administrative matter, and
does not affect the general jurisdiction of said courts; When an intra-corporate dispute is
raffled to a regular RTC branches, not designated as a commercial court, the remedy is not
dismissal but the re-docketing of the case; Designation as a Special Commercial Court does
not remove the general jurisdiction of such courts over ordinary civil cases
Facts: Manuel Gonzales and Francis Gonzales (petitioners) filed a Complaint for Injunction
with Damages against respondents GJH Land, Inc. (formerly S.J. Land, Inc.) and individual
respondents 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. on February 1, 2010. 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 raffled to Branch 276, which is not a Special Commercial Court. Said branch
issued a temporary restraining order (TRO) and later, in an Order dated August 24, 2011,
granted the application for a writ of preliminary injunction.
The 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 dispute and should,
thus, be heard by the designated Special Commercial Court of Muntinlupa City.
Branch 276 granted the motion to dismiss filed by respondents. It found that the case
involves an intra-corporate dispute. Since 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.
Branch 276 denied the motion for reconsideration, holding that it has no authority or
power to order the transfer of the case to the proper Special Commercial Court, citing
Calleja v. Panday.
Hence, the present petition. The issue for tresolution is whether or not Branch 276 of the
RTC of Muntinlupa City erred in dismissing the case for lack of jurisdiction over the subject
matter.
Held:
Nature of the case as an intra-corporate dispute
1.Branch 276 [has] correctly categorized [the present case] 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.
2.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 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 RA
8799.
Jurisdiction vs. Exercise of jurisdiction
3.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.
4.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.
RA 8799 vested jurisdiction in the RTC as courts of general jurisdiction
5.By virtue of Item 5.2, Section 5 of RA 8799, which took effect on August 8, 2000,
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.
6.Item 5.2, Section 5 of RA 8799 provides:
5.2 The Commission's jurisdiction over all cases enumerated under Section 5 of Presidential
Decree No. 902-A is hereby transferred to the Courts of general jurisdiction or the
appropriate Regional Trial Court:Provided, that the Supreme Court in the exercise of its
authority may designate the Regional Trial Court branches that shall exercise jurisdiction
over the cases. T
7.The regional trial court, formerly the court of first instance, is a court of general
jurisdiction. All cases, the jurisdiction over which is not specifically provided for by law to be
within the jurisdiction of any other court, fall under the jurisdiction of the regional trial
court.
8.To clarify, the word "or" in Item 5.2 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." The word "or" may be used as the equivalent
of "that is to say" and gives that which precedes it the same significance as that which
follows it. It is not always disjunctive and is sometimes interpretative or expository of the
preceding word.
9.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.
Designation of certain RTCs as Special Commercial Courts is an administrative matter, and
does not affect the general jurisdiction of said courts
10.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
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, i.e., the Special Commercial Court, to
streamline the court structure and to promote expediency. 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.
11.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.
When an intra-corporate dispute is raffled to a regular RTC branches, not designated as a
commercial court, the remedy is not dismissal but the re-docketing of the case
12.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, e.g., 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 more importantly, cannot prevail over its actual allegations that clearly
make out an intra-corporate dispute.
13.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, but instead:
(a)when the RTC has only one special commercial court branch — The regular RTC branch
should refer 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.
(b)when the RTC 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.
(c)when the RTC has no branch designated as a Special Commercial Court — 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.
14.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.
15.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. (see Tan v. Bausch & Lomb, Inc.)
16.The RTC mistakenly relied on the Calleja case to support its ruling. 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.
Designation as a Special Commercial Court does not remove the general jurisdiction of such
courts over ordinary civil cases
17.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.
18.Unlike the limited assignment/raffling of a commercial case only to branches designated
as Special Commercial Courts in the scenarios stated above, the re-raffling of an ordinary
civil case in this instance to all courts is permissible due to the fact that a particular branch
which has been designated as a Special Commercial Court does not shed the RTC's general
jurisdiction over ordinary civil cases under the imprimatur of statutory law, i.e., Batas
Pambansa Bilang (BP) 129.
19.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 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 court procedure.
1) SANTE v. CLARAVAL
Petitioners filed a Motion to Dismiss on the ground that it was the Municipal Trial Court in
Cities (MTCC) and not the RTC of Baguio, that had jurisdiction over the case. They argued
that the amount of the claim for moral damages was not more than the jurisdictional
amount of ?300,000.00, because the claim for exemplary damages should be excluded in
computing the total claim.
Aggrieved, petitioners filed on August 2, 2004, a Petition for Certiorari and Prohibition,10
docketed as CA-G.R. SP No. 85465, before the Court of Appeals. Meanwhile, on July 14,
2004, respondent and her husband filed an Amended Complaint INCREASINGthe claim for
moral damages from ?300,000.00 to ?1,000,000.00.
*If damages is the MAIN CAUSE OF ACTION, other damages of whatever kind are INCLUDED
in determining the jurisdiction of the court.
*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,23 here, the RTC clearly had jurisdiction over the
original complaint and amendment of the complaint was then still a matter of right.
PETITION DENIED.
2) SEBASTIAN v. NG
She claimed that Annabel and Michael were once sweethearts, and that they agreed to
jointly invest their financial resources to buy a truck. She alleged that while Annabel was
working in Hongkong, Annabel sent Michael 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.
The MCTC has the authority and jurisdiction to enforce the kasunduan regardless of the
amount involved.
The Court also finds that the CA correctly upheld the MCTC's jurisdiction to enforce any
settlement or arbitration award issued by the Lupon.
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.
PETITION DENIED.
3) BARRIDO v. NONATO
respondent Leonardo V. Nonato and petitioner Marietta N. Barrido,they were able to
acquire a property situated in Eroreco, Bacolod City, consisting ofa house and lot, covered
by Transfer Certificate of Title (TCT) No. T-140361. 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. Thus, on January 29, 2003, Nonato filed a Complaint for partition before the
Municipal Trial Court in Cities (MTCC) of Bacolod City, Branch 3.
Barrido claimed, by way of affirmative defense, that the subject property had already been
sold to their children, Joseph Raymund and Joseph Leo. She likewise moved for the
dismissal of the complaint because the MTCC lacked jurisdiction, the partition case being an
action incapable of pecuniary estimation.
*Here, the subject property’s assessed value was merely ?8,080.00, an amount which
certainly does not exceed the required limit of ?20,000.00 for civil actions outside Metro
Manila tofall within the jurisdiction of the MTCC. Therefore, the lower court correctly took
cognizance of the instant case
PETITION DENIED.
4) BRGY SAN ROQUE v. PASTOR
An EXPROPRIATION suit is INCAPABLE of PECUNIARY ESTIMATION. Accordingly, it falls
within the jurisdiction of the RTC, regardless of the value of the subject property.
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.
PETITION GRANTED.
5) GONZALES v. GJH land
seeking to enjoin the sale of S.J. Land, Inc.'s shares which they purportedly bought from S.J.
Global, Inc. on February 1, 2010. 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.,7 but were nonetheless offered for sale
on July 29, 2011 to the corporation's stockholders,8 hence, their plea for injunction.
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.

when a commercial case - such as the instant intra-corporate dispute - has been properly
filed in the official station of the designated Special

Commercial Court but is, however, later WRONGLY ASSIGNED BY RAFFLE to a regular
branch of that station.

PETITION GRANTED.