Jurisdiction of Philippine Courts Notes
Jurisdiction of Philippine Courts Notes
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be referred to the Court of Appeals for appropriate action. The Supreme
Court in this particular case does not have to dismiss an improper appeal.
Exceptions:
1. When the conclusion is a finding grounded entirely on
speculation, surmises and conjectures;
2. When the inference made is manifestly mistaken, absurd or
impossible;
3. Where there is grave abuse of discretion;
4. When the judgement is based on a misapprehension of facts;
5. When the findings of facts are conflicting;
6. When the CA went beyond the issues of the case in making its findings
and is contrary to the admissions of the parties;
7. When the findings are contrary to those of the trial court;
8. When the findings of fact are conclusions without citation of specific
evidence on which they are based;
9. When the facts set forth in the petition as well as in the petitioner’s
main and reply brief are not disputed by the respondents; and
10. When the findings of fact of the CA is premised on a supposed
absence of evidence but is contradicted by the evidence on
record. [Aklan vs Enero, G. R. No. 178309, 2009]
EXCLUSIVE ORIGINAL JURISDICTION
Petitions for certiorari, prohibition and mandamus against appellate
courts, namely:
1. Court of Appeals;
2. Court of Tax Appeals;
3. Commission on Elections;
4. Commission on Audit
5. Sandiganbayan
CONCURRENT ORIGINAL JURISDICTION
1. With the CA
a. Petitions for certiorari, prohibition and mandamus against first-
level courts and bodies, namely
i. RTCs
ii. Civil Service Commission
iii. Central Board of Assessment Appeals
iv. NLRC [St. Martin Funeral Homes vs. NRLR, G.R. No. 130866] ;
and
v. Other quasi-judicial agencies [ Heirs of Hinog v. Melicor,
G.R. No. 140954]
b. Quo Warranto petitions;
c. Writ of Habeas Corpus petitions;
d. Writ of Amparo,
e. Writ of Habeas Data; and
f. Writ of Kalikasan.
2. With the RTC
a. Cases affecting ambassadors, public ministers and consuls;
b. Petitions for certiorari, prohibition and mandamus against lower
courts;
c. Quo Warranto petitions;
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d. Writ of Habeas Corpus;
e. Writ of Amparo; and
f. Writ of Habeas Data
Writ of Kalikasan
3. With Sandiganbayan
a. Writ of Amparo; and
b. Writ of Habeas Data
APPELLATE JURISDICTION [ Article VIII, Section 5 (par. 2), of the
Constitution]
3) The Supreme Court shall have appellate jurisdiction by way of petition for
review on certiorari (appeal by certiorari under RULE 45) against the:
a) (a) Court of Appeals; (b) Sandiganbayan; (c) RTC on pure questions of
law and in cases involving the constitutionality or validity of a law or a
treaty, international or executive agreement, law, presidential decree,
proclamation, order, instruction, ordinance or regulation, legality of a tax,
impost, assessment, toll or penalty, jurisdiction of a lower court, and (d)
Court of Tax Appeals in its decisions rendered en banc [Section 5,
Article VIII of the Constitution]
CASES WHICH MUST BE HEARD EN BANC [Article VIII, Section 4, of the
Constitution]
Article VIII, Section 4. Of The Constitution
(1) xxx
(2) a. All cases involving the constitutionality of a treaty, international
or executive agreement, or law;
b. all other cases which under the Rules of Court are required to be
heard en banc;
c. including those involving the constitutionality, application, or
operation of presidential decrees, proclamations, orders, instructions,
ordinances, and other regulations;
(3) d. Cases or matters heard by a division when the required number
in the division is not obtained,
e. no doctrine or principle of law laid down by the court in a
decision rendered en banc or in division may be modified or reversed
except by the court sitting en banc.
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7) By way of petition for review from decisions, resolutions, orders or awards
of the Civil Service Commission, and other bodies mentioned in Rule 43,
Rules of Court
APPELLATE JURISDICTION
8) Over decisions of the Municipal Trial Court in cadastral and land registration
cases pursuant to its delegated jurisdiction because decisions of the
Municipal Trial Courts in these cases are appealable in the same
manner as decisions of the Regional Trial Court
9) Decisions of the Office of the Ombudsman in administrative disciplinary cases
CONCURRENT ORIGINAL JURISDICTION
1. With the SC
a. Petitions for certiorari, prohibition and mandamus against first-level
courts and bodies, namely;
i. RTC;
ii. NLRC;
iii. Civil Service Commission;
iv. Central Board of Assessment Appeals;
v. Other Quasi-judicial Agencies
b. Quo Warranto;
c. Habeas Corpus;
d. Writ of Amparo;
e. Habeas Data;
f. Writ of Kalikasan
2. With the RTC
a. Petition for certiorari, prohibition and mandamus against lower
courts and bodies
b. Quo warranto petitions;
c. Writ of habeas corpus;
d. Writ of amparo
e. Habeas data
3. With the Sandiganbayan
a. Writ of Amparo
b. Writ of Habeas data
POWER TO TRY AND CONDUCT HEARINGS LIKE A TRIAL COURT
Sec. 9[3], BP 129, as amended by RA 7902
10) “the Court of Appeals shall have the power to try cases and conduct
hearings, receive evidence and perform any and all acts necessary to resolve
factual questions raised in cases falling (not only) within its original (but
also) and appellate jurisdiction, including the power to grant and conduct
new trials and further proceedings x x x” [PNB vs. Pasimio, G.R. No.
205590, 2015]
Limitations
a. The trials and hearings must be continuous; and
b. Must be decided within 3 months unless extended by the Supreme Court
JURISDICTION OF THE COURT OF TAX APPEALS [RA 9282]
EXCLUSIVE ORIGINAL JURISDICTION
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1. Over tax collection cases involving final and executory assessments for
taxes, fees, charges, and penalties; provided however, that collection
cases where the principal amount of taxes and fees exclusive of charges
and penalties claimed, is less than P1,000,000.00 shall be tried by the
proper MTC, Metropolitan Trial Court and Regional Trial Court.
2. Over tax collection cases
a. Over appeals from the judgement, resolutions or orders of the
Regional Trial Courts in tax collection cases originally decided by
them, in their respective territorial jurisdiction
b. Over petitions for review of the judgements, resolutions or orders of
the RTC in the exercise of their appellate jurisdiction over tax
collection cases originally decided by the MTCs in their respective
jurisdiction
JURISDICTION OF THE SANDIGANBAYAN
Exclusive Original
CIVIL CASES CRIMINAL CASES
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position
classified as “Grade 27” and higher.
(Sec. 4,
P.D. No. 1606, as amended by R.A. No.
8249)
6. Inclusion or exclusion of voters
(Sec. 138, B.P. No. 881);
7. Those covered by the Rules on
Summary
Procedure:
8. Forcible entry and unlawful
detainer;
9. Those covered by the Rules on
Small Claims, i.e.,
actions for payment of money where the
claim
does not exceed P 400,000 exclusive of
interest
and costs for the METCs and P 300,000 for
the
MTCCs, MTCs, and MCTCs. (A.M. No. 08-8-
7-SC, as
amended, effective April 1, 2019)
Delegated
Cadastral or land registration cases covering
lots where: 1. There is no controversy or
opposition; 2. Contested, but the value does
not exceed P100,000 (Sec. 34, BP 129, as
amended by R.A. No. 7691) NOTE: The value
shall be ascertained by the affidavit of the
claimant or agreement of the respective
claimants. (Sec. 34, B.P. No. 129 as amended
by R.A. No. 7691)
Special
Petition for habeas corpus in the absence of all Application for bail in the absence of all
RTC judges in the province or city. (Sec. 35, B.P. RTC judges in the province or city
No. 129)
with RTC
Cases involving enforcement or violations of
environmental and other related laws, rules
and regulations. (Sec. 2, Rule 1, A.M. No. 09-6-
8-SC)
Real Actions where the assessed value of the property does not exceed
P400,000.00
- Real actions are defined as actions involving title, possession or any
interest to real properties. These actions include actions for recovery of
ownership, possession or quieting of title over real properties. Jurisdiction
over such actions is shared between the MTC and the RTC depending on
the assessed value of the property as reflected by the tax declaration or
the allegation in the complaint by the party. Take note that in real actions,
the complainant must allege the assessed value of the property otherwise,
the court does not acquire jurisdiction over the case. Jurisdiction of the
court includes the authority to examine whether an action is within its
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jurisdiction based on the material allegations, the main cause of action or
the relief sought. Without such assessed value, the court does not have
any basis to acquire such jurisdiction. Thus, it would be error for the court
not to dismiss the action. However, the rule is not without exception. The
failure to allege the assessed value of the property is not fatal if there is a
tax declaration over such property attached to the complaint. For
properties not declared for taxation purposes, the assessed value shall be
determined by the assessed value of the adjacent lots.
o It is also important to note that assessed value of the property is
immaterial on appeal. The assessed value is only material when the
court is exercising its original jurisdiction.
Accion publiciana, Accion Reivendicatoria
- An accion publiciana is a plenary action within the jurisdiction of the
regular courts for the recovery of possession over a real property,
independently of the issue of ownership. However, issues as to the
ownership of the property may be heard and provisionally determined,
if it such issue is so intertwined that the issue of possession cannot be
settled without first settling the issue on ownership. Such determination
however is not a bar to a subsequent filing of another action relating to
such issue. As opposed to an accion interdictal, an accion publiciana is a
plenary action which means a full blown trial is needed to settle the same.
It may filed when the grounds for an accion interdictal is not present such
as former lawful possession or fraud, intimidation, threat, stealth and
strategy or when the dispossession has already exceeded one year.
- An accion reivendicatoria on the other hand, is an action for the recovery
of possession over a property based on ownership.
JURISDICTION OF REGIONAL TRIAL COURTS
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3. Actions in admiralty and 3. Other laws which specifically lodge
maritime jurisdiction where jurisdiction in the RTC:
demand or claims exceed a. Law on written defamation or
P2,000,000.00 libel;
b. Decree on Intellectual Property;
and
c. Violations of Dangerous Drugs
Act regardless of the imposable
penalty except when the offender
is under 16 and there are Juvenile
and Domestic Relations Court in
the province
4. Probate proceedings, both4. Cases falling under the Family
testate and intestate, where the Courts in areas where there are no
value of the estate exceeds Family Courts (Sec. 24, B.P. No. 129);
P2,000,000.00 and
5. All actions involving contract of 11) 5. Election offenses
marriage and marital relations (Omnibus Election Code) even if
– note that this jurisdiction is committed by an official with
deemed modified by Sec. 5 of RA salary grade of 27 or higher
8639, which establishes the Family
Courts. However, in areas where
there is no family courts, Sec. 5 of
the law shall be adjudicated by the
RTC
1. General jurisdiction – all actions
not within the exclusive jurisdiction
of any court, tribunal, person or
body exercising judicial or quasi-
judicial functions
2. All civil actions and special
proceedings falling within the
exclusive original jurisdiction of the
Juvenile and Domestic
Relations Court and of the Court
of Agrarian Relations as now
provided by law
3. All cases where the demand or the
value of the personal property
exceed 2 million pesos,
exclusive of interest, damages of
whatever kind, attorneys’ fees,
cost and litigation expense
Appellate
GR: All cases decided by lower courts in their respective territorial
jurisdictions.
XPN: Decisions of lower courts in the exercise of delegated jurisdiction. (Sec.
22, B.P. No. 129
Concurrent with the SC
All cases affecting ambassadors,
public ministers and consuls
Concurrent with the SC and CA
1. Petitions for mandamus,
certiorari, and prohibitions
against lower courts and
bodies;
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2. Petitions for habeas corpus
and Quo Warranto
Concurrent with the MTC
Cases involving enforcement or
violations of environmental and other
related laws, rules and regulations.
(Sec. 2, Rule 1, A.M. No. 09-6-8-SC
Special Jurisdiction
Supreme Court may designate certain branches of RTC to try exclusively:
1. Criminal cases;
2. Juvenile and domestic relations cases;
3. Agrarian cases;
4. Urban land reform cases not falling within the jurisdiction of any quasi-
judicial body; and
5. Other special cases as the SC may determine in the interest of a
speedy and efficient administration of justice. (Sec. 23, B.P. No. 129)
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Jurisdiction over actions incapable of pecuniary estimation
1. Subject to Principal Relief Sought, ultimate objective test,
- The rule of thumb is if the action involves recovery of a sum of money,
the action is capable of pecuniary estimation and jurisdiction over
which is determined by the amount of demand. Examples are action for
reformation of a contract, specific performance, and rescission of contract
– incapable of pecuniary estimation
- Take note that an action for the annulment of extrajudicial foreclosure
sale of property is an action incapable of pecuniary estimation -
- In case where the relief sought is in the alternative, one for specific
performance or in the alternative to pay a certain sum of money, the case
is one capable of pecuniary estimation since one of the claims is for
sum of money.
- An action for the recovery of personal property is an action capable
of pecuniary estimation considering the value of the personal property.
- An action based on a quasi-delict is capable of pecuniary estimation
which is primarily based on damages. Exception to the exclusions
- An action for injunction is incapable of pecuniary estimation
- an action for interpleader where the subject matter is either personal or
real property is capable of pecuniary estimation, however when the
subject matter is to determine who is entitled to specific performance
then the subject matter is one incapable of pecuniary estimation.
- Where in an action for the declaration of nullity and for partition, it was
found that the case is mainly for the declaration of nullity of the
documents in question and although partition of the property is also
sought, the same is merely incidental to the main action.
- NOTE:
o A review of jurisprudence in determining whether the action is one
incapable of pecuniary estimation, the court has adopted the
criterion of first ascertaining the nature of the principal action
or the remedy sought.
o Thus, in the annulment of an instrument, and the property has not
yet been conveyed to the other party or that the ownership has
not yet transferred, it is deemed to be one incapable of
pecuniary estimation.
o As an example in a case for annulment of real estate mortgage, the
complainant did not expressly or impliedly sought the recovery of
the property sold to respondents because it still had ownership
and possession over the property, thus it never asserted
recovery.
o In another case, the annulment was based on the invalidity of the
real estate mortgage and thus one incapable of pecuniary
estimation.
o Breach of contract is one capable of pecuniary estimation on
damages
- Incapable of Pecuniary Estimation
o Whatever confusion there might have been regarding the nature of
actions for nullity of contracts or legality of conveyances, which
would also involve recovery of sum of money or real property, was
directly addressed by Lu v. Lu Ym, 563 SCRA 254 (2008). Lu
underscored that “where the basic issue is something other than
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the right to recover a sum of money, the money claim being
only incidental to or merely a consequence of, the principal relief
sought, the action is incapable of pecuniary estimation.” This finds
support in numerous decisions where this Court proclaimed that the
test to determine whether an action is capable or incapable of
pecuniary estimation is to ascertain the nature of the principal
action or relief sought.
o Thus, if the principal relief sought is the recovery of a sum of
money or real property, then the action is capable of pecuniary
estimation. However, if the principal relief sought is not for the
recovery of money or real property and the money claim is only a
consequence of the principal relief, then the action is incapable of
pecuniary estimation. First Sarmiento Property Holdings, Inc. vs.
Philippine Bank of Communications , 866 SCRA 438, G.R. No.
202836 June 19, 2018
o Rescission of contract, is one incapable of pecuniary estimation
- Injunction;
- Rescission or annulment of contract – subject to ultimate objective test.
- Declaratory relief;
- Specific performance – still considered specific performance if the
provision in the contract consists of payment of a sum of money. Specific
performance because it is the compliance with the provision which is
sought to be enforced, incidentally consisting of a sum of money payment
or refund.
- Action for revival of judgement;
- Citizens suit
- Action for abatement of nuisance
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