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JURISDICTION OF THE

REGIONAL TRIAL
COURTS

Marie Immaculate L. Clemente


EXCLUSIVE ORIGINAL JURISDICTION

1. Actions in which the subject of litigation is incapable of pecuniary


estimation;

2. Actions involving title to or possession of real property or any


interest therein where the assessed value exceeds Php 20,000 or
Php 50,000 in Metro Manila, except forcible entry and unlawful
detainer;

3. Actions in admiralty and maritime jurisdiction where demand or


claim exceeds Php 300,000 or Php 400,000 in Metro Manila;

4. Matters of probate, testate or intestate, where gross value of estate


exceeds Php 300,000 or Php 400,000 in Metro Manila;
EXCLUSIVE ORIGINAL JURISDICTION

5. In all actions involving the contract of marriage and marital


relations;

6. Cases not within the exclusive jurisdiction of any court , tribunal,


person or body exercising judicial or quasi-judicial function;

7. Civil actions and special proceedings falling within exclusive


original jurisdiction of Juvenile and Domestic Relations Court and
Court of Agrarian Reforms;

8. Other cases where the demand, exclusive of interest , damages,


attorney ’s fees, litigation expenses and costs, or value of property in
controversy exceeds P300,000 or Php 400,000 in Metro Manila; and

9. Intra-corporate controversies under Sec. 5.2 of the Securities and


Regulation Code.
CONCURRENT JURISDICTION

• With the SC, SB, and CA


1. Writ of Amparo
2. Writ of Habeas Data

• With the SC
Actions affecting ambassadors and other public ministers and consuls.

• With SC and CA
1. Certiorari, prohibition and mandamus against lower courts and
bodies;
2. Habeas corpus and Quo Warranto;

• With the MTC


Cases involving enforcement or violations of environmental and other
related laws, rules and regulations.
APELLATE JURISDICTION

1. Over all cases decided by the Metropolitan Trial Courts,


Municipal Trial Courts, and Municipal Circuit Trial Courts in
their respective territorial jurisdictions.

2. Decisions of the RTC in the exercise of its appellate


jurisdiction shall be appealable by petition for review to the
CA.
SPECIAL JURISDICTION

SC may designate certain branches of RTC to try


exclusively criminal cases, juvenile and domestic
relations cases, agrarian cases, urban land reform
cases not falling within the jurisdiction of any quasi-
judicial body and other special cases in the interest of
justice
JURISDICTION OVER INTRA -CORPORATE
CONTROVERSIES

1. Devices or schemes employed by, or any act of, the board of


directors, business associates, officers or partners, amounting to
fraud or misrepresentation which may be detrimental to the interest
of the public and/or of the stockholders, partners, or members of any
corporation, partnership, or association;

2. Controversies arising out of intra-corporate, partnership, or


association relations, between and among stockholders, members, or
associates; and between, any or all of them and the corporation,
partnership, or association of which they are stockholders, members,
or associates, respectively ;
JURISDICTION OVER INTRA -CORPORATE
CONTROVERSIES

3. Controversies in the election or appointment of directors, trustees,


officers, or managers of corporations, partnerships, or associations;

4. Derivative suits; and

5. Inspection of corporate book


T WO TESTS IN DETERMINING WHETHER OR NOT THE
CONTROVERSY INVOLVES INTRA -CORPORATE ISSUES:

1. The Relationship Test


2. Nature of the Controversy Test
T WO TESTS IN DETERMINING WHETHER OR NOT THE
CONTROVERSY INVOLVES INTRA -CORPORATE ISSUES:

1. The Relationship Test

1. Between the corporation, partnership or association and the


public;

2. Between the corporation, partnership or association and the


State insofar as its franchise, permit or license to operate is
concerned;

3. Between the corporation, partnership or association and


its stockholders, partners, members or officers; and

4. Among the stockholders, partners or associates themselves .


T WO TESTS IN DETERMINING WHETHER OR NOT THE
CONTROVERSY INVOLVES INTRA -CORPORATE ISSUES:

2. Nature of the Controversy Test

Controversy not only rooted in the existence of intra-


corporate relationship, but also to the enforcement of parties’
correlative rights and obligations under the Corporation Code or
rules of the corporation .
MEDICAL PLAZA MAKATI CONDOMINIUM
CORPORATION VS. CULLEN

FACTS:

 Respondent Robert H. Cullen purchased from MLHI condominium


Unit No. 1201 of the Medical Plaza Makati.
 On September 19, 2002, petitioner, through its corporate secretary,
Dr. Jose Giovanni E. Dimayuga, demanded from respondent payment
for alleged unpaid association dues and assessments amounting to
₱145,567.42.
 Defense of Respondent: Claiming that he had been religiously
paying his dues shown by the fact that he was previously elected
president and director of petitioner.
 Petitioners Argument: Claimed that Cullen’s obligation was a
carry-over of that of MLHI.
 Consequence: respondent was prevented from exercising his right
to vote and be voted for during the 2002 election of petitioner’s
Board of Directors.
MEDICAL PLAZA MAKATI CONDOMINIUM
CORPORATION VS. CULLEN

 Cullen thus clarified from MLHI the veracity of petitioner’s claim,


but MLHI allegedly claimed that the same had already been settled.
This prompted Cullen to demand from petitioner an explanation why
he was considered a delinquent payer despite the settlement of the
obligation. Petitioner failed to make such explanation. Hence, the
Complaint for Damages filed by respondent against petitioner and
MLHI.
 Petitioner and MLHI filed their separate motions to dismiss the
complaint on the ground of lack of jurisdiction.

 MLHI Contentions: MLHI claims that it is the Housing and Land Use
Regulatory Board (HLURB) which is vested with the exclusive
jurisdiction to hear and decide the case.
MEDICAL PLAZA MAKATI CONDOMINIUM
CORPORATION VS. CULLEN

 RTC DECISION: The trial court agreed with MLHI that the action for
specific performance filed by respondent clearly falls within the
exclusive jurisdiction of the HLURB.

 CA DECISION: the CA reversed and set aside the trial court’s


decision and remanded the case to the RTC for further proceedings.

 ISSUE: Whether or not the controversy involve intra-corporate


issues as would fall within the jurisdiction of the RTC.
MEDICAL PLAZA MAKATI CONDOMINIUM
CORPORATION VS. CULLEN

 HELD:

An intra-corporate controversy is one which pertains to any of


the following relationships:
(1) between the corporation, partnership or association and
the public;
(2) between the corporation, partnership or association and
the State insofar as its franchise, permit or license to operate
is concerned;
(3) between the corporation, partnership or association and
its stockholders, partners, members or officers; and
(4) among the stockholders, partners or associates
themselves.
MEDICAL PLAZA MAKATI CONDOMINIUM
CORPORATION VS. CULLEN

Admittedly, petitioner is a condominium corporation duly


organized and existing under Philippine laws, charged with the
management of the Medical Plaza Makati. Respondent , on the other
hand, is the registered owner of Unit No. 1201 and is thus a
stockholder/member of the condominium corporation. Clearly, there
is an intra-corporate relationship between the corporation and a
stockholder/member.

Thus, the intra-corporate dispute between petitioner and


respondent is still within the jurisdiction of the RTC sitting as a
special commercial court and not the HLURB.
COURT OF GENERAL JURISDICTION

All cases, the jurisdiction of which is not


specifically provided by law to be within the
jurisdiction of any other court falls within the
jurisdiction of the Regional Trial Court.
ACTIONS INCAPABLE OF PECUNIARY
ESTIMATION

The basic issue in an action incapable of pecuniary


estimation is one other than the recovery of money. In this kind
of action the money claim is merely incidental.

If the action is one primarily for the recovery of money,


the claim is considered capable of pecuniary estimation
ACTIONS INCAPABLE OF PECUNIARY
ESTIMATION

ILLUSTRATIONS:

1. A complaint for expropriation is incapable of pecuniary


estimation (Barangay San Roque vs. Heirs of Pastor)

2. An action to annul a Deed of Declaration of Heirs and for


a partition of land with an assessed value of P5,000.00 is an
action incapable of pecuniary estimation where the partition
aspect is only incidental to the action for annulment
(Russelvs.Vestil)
ACTIONS INCAPABLE OF PECUNIARY
ESTIMATION

ILLUSTRATIONS:

3. An action for specific performance is one generally


considered incapable of pecuniary estimation (Russel vs. Vestil,
supra.)

4. The amount of damages that may be claimed in addition


to the prayer for specific performance is not determinative of
jurisdiction. Thus, an action for specific performance and
damages of P200,000.00 is cognizable by the Regional Trial
Court even if the amount of damages sought to be recovered is
within the jurisdiction of the Municipal Trial Court.
ACTIONS INCAPABLE OF PECUNIARY
ESTIMATION

ILLUSTRATIONS:

5. An action for a writ of injunction is within the


jurisdiction of the Regional Trial Court. It is an action incapable
of pecuniary estimation.

6. An action for the replevin of a motorcycle valued at


P150,000.00 is capable of pecuniary estimation. The basis of
jurisdiction is the value of the personal property sought to be
recovered. The amount of P150,000.00 falls within the
jurisdiction of the MTC.
ACTIONS INCAPABLE OF PECUNIARY
ESTIMATION

QUESTION:

Plaintiff filed with the RTC an action for Specific


Performance to compel a builder to finish the construction of a
house or to pay him the sum of P250,000. The Defendant Builder
filed a motion to dismiss on the ground that jurisdiction is with
the MTC. The plaintiff opposed the motion to dismiss arguing
that the complaint to compel defendant to finish the
construction is one for specific performance and thus an action
incapable of pecuniary estimation.

Should the RTC grant the motion to dismiss?


ACTIONS INCAPABLE OF PECUNIARY
ESTIMATION

ANSWER:

YES. The alternative relief for damages made the action


for specific performance capable of pecuniary estimation.
Hence, the jurisdiction lies with the MTC since the amount of
the claim does not exceed P300,000.
ACTIONS INCAPABLE OF PECUNIARY
ESTIMATION

QUESTION:

Would your answer be the same if what the Plaintiff


filed was an action for specific performance to compel the
builder to finish the construction of the house and to pay
him P250,000?
ACTIONS INCAPABLE OF PECUNIARY
ESTIMATION

ANSWER:

NO. The action would be for specific performance and


thus incapable of pecuniary estimation. The claim for P250,000
is not equivalent of the action for specific performance since it
was prayed for as additional rather than an alternative relief.
JURISDICTION WHEN ACTING
AS PROBATE COURT

1. Determine whether properties claimed to be part of the


estate should or should not be included in the inventory or list
of properties to be administered subject to a final determination
in a separate action.

2. However, if the interested parties are all heirs, or the


parties consent to the assumption of jurisdiction by the probate
court and third parties are not prejudiced or injured thereby,
the probate court may decide questions on ownership.

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