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Jurisdiction of the RTC

Outline – Jurisdiction of the RTC • Introduction • Jurisdiction 1. 2. 3. 4.

Exclusive Original Jurisdiction Concurrent Original Jurisdiction Special Jurisdiction Appellate Jurisdiction

• Family Courts

How many RTCs are there? • Section 13 of BP 129. Creation of Regional Trial Courts. – There are hereby created thirteen (13) Regional Trial Courts, one for each of the following judicial regions.

• 13 Judicial Regions; Every division is divided into branches and the number of branches keeps on increasing by law.

• BP 129, Section 18 . Authority to define territory appurtenant to each branch – The Supreme Court shall define the territory over which a branch of the Regional Trial Court shall exercise its authority. The territory thus defined shall be deemed to be the territorial area of the branch concerned for purposes of determining the venue of all suits, proceedings or actions, whether civil or criminal, as well as determining the Metropolitan Trial Courts, Municipal Trial Courts, and Municipal Circuit Trial Courts over which the said branch may exercise appellate jurisdiction. The power herein granted shall be exercised with a view to making the courts readily accessible to the people of the different parts of the region and making the attendants of litigants and witness as inexpensive as possible.

Exclusive original jurisdiction 1. Actions wherein the subject matter is not capable of pecuniary estimation When is an action incapable of pecuniary estimation? What is the test? In determining whether an action is one the subject matter of which is not capable of pecuniary estimation 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 RTCs would depend on the amount of the claim. But where the basic issue is something other than the right to recover a sum of money, where the money claim is purely incidental to, or a consequence of, the principal relief sought, this Court has considered such actions as cases where the subject of the litigation may not be estimated in terms of money, and, hence, are incapable of pecuniary estimation. (Heirs of Bautista v. Lindo, G.R. No. 208232, March 10, 2014)

Exclusive original jurisdiction Examples of actions which are incapable of pecuniary estimation: 1. Actions for specific performance 2. Actions for support which will require the determination of the civil status 3. The right to support of the plaintiff 4. Annulment of decisions of lower courts 5. Rescission or reformation of contracts 6. Interpretation of a contractual stipulation 7. Actions questioning the validity of a mortgage 8. Annulling a deed of sale or conveyance and to recover the price paid 9. Expropriation

Exclusive original jurisdiction GR: All actions incapable of pecuniary estimation fall within the original jurisdiction of the RTC. E: Annulment of judgments of the RTC. *The Court of Appeals has exclusive original jurisdiction over actions for annulment of judgments of RTCs (see Section 9 of BP 129).

Exclusive original jurisdiction Q: Is foreclosure of mortgage an action incapable of pecuniary estimation? There seems to be contrary rulings to this matter. According to the 1999 case of Russell v. Vestil, it is incapable of pecuniary estimation. There are also cases that say it is capable of pecuniary estimation. This issue was clarified in the 2018 case of Roldan v. Barrios, where the Supreme Court held that: “Petitioner cites Russell v. Vestil to show that action for foreclosure of mortgage is an action incapable of pecuniary estimation and, therefore, within the jurisdiction of the RTC. We are not persuaded. While actions under Sec. 33(3) of B.P. 129 are also incapable of pecuniary estimation, the law specifically mandates that they are cognizable by the MTC, METC, or MCTC where the assessed value of the real property involved does exceed ₱20,000.00 in Metro Manila, or ₱50,000.00, if located elsewhere. If the value exceeds ₱20,000.00 or ₱50,000.00 as the case may be, it is the Regional Trial Courts which have jurisdiction under Sec. 19(2). However, the subject matter of the complaint in this case is annulment of a document denominated as "DECLARATION OF HEIRS AND DEED OF CONFIRMATION OF PREVIOUS ORAL PARTITION. Clearly, the last paragraph clarified that while civil actions which involve title to, or possession of, real property, or any interest therein, are also incapable of pecuniary estimation as it is not for recovery of money, the court's jurisdiction will be determined by the assessed value of the property involved.”

Exclusive original jurisdiction 2. Actions involving title to or possession of real property or an interest therein, where the assessed value of such property exceeds PhP 20,000.[in Metro Manila, PhP 50,000.] • Exception: Forcible Entry and Unlawful Detainer Real Actions: 1. accion publiciana, 2. accion reinvindicatoria, 3. quieting of title, provided the value of the property exceeds P20,000.00/P50,000.00 based on the assessed value of the property.

Exclusive original jurisdiction 3. Actions in admiralty and maritime jurisdiction (depending on the amount) 4. Matters of probate, testate or intestate (depending on the gross value of the estate) 5. Demand for money (depending on amount) Test: Claim for amount for must be EXCLUSIVE of interest, damages, attorney’s fees, litigation expenses and costs Rule: If the value of the claim is > P300,000/400,000 – RTC If the value of the claim is = or < P300,000/400,00 – MTC

Exclusive original jurisdiction Q: Suppose, the claim is exclusive of damages, where do you file the claim? A: It depends on the total amount of the claim. This matter has been clarified in SC Administrative Circular No. 09-94: The exclusion of the term "damages of whatever kind" in determining the jurisdictional amount under Section 19 (8) and Section 33 (1) of B.P. Blg. 129, as amended by R.A. No. 7691, applies to cases where the damages are merely incidental to or a consequence of the main cause of action. However, in cases where the claim for damages is the main cause of action, or one of the causes of action, the amount of such claim shall be considered in determining the jurisdiction of the court.

Exclusive original jurisdiction Restating the Rule: If the damages is only incidental to the claim, exclude the damages. But if the claim is purely for damages, compute if the total damages exceed P300k/P400k to determine the jurisdiction. Example 1: A filed a case against B for recovery of personal property (worth P100k) + moral damages (P400k) + exemplary damages (P100k). Where do you file the case? Answer: A must file the case with the MTC, since the primary claim is below P300k/P400k. The main action here in this case is the recovery of property; the recovery of damages is only incidental to the main action. Example 2: A filed a case for breach of contract of carriage against Cebu Pacific for actual damages (P15k = price of ticket) + moral damages of P300k + exemplary damages of P150k + attorney’s fees of P50k. Where do you file the case? Answer: A must file it with the RTC since the aggregate amount of damages sought is more than P300k/P400k.

Exclusive original jurisdiction 6. Actions and special proceedings within the exclusive original jurisdiction of the former Juvenile and Domestic Relations Court and of the Court of Agrarian Relations • Juvenile and Domestic Relations Court is now the Family Courts (R.A. 8369) • Court of Agrarian Relations • Under the Comprehensive Agrarian Reform Law (R.A. 6657), all agrarian disputes between landlord and tenant, lessor and lessee were transferred to the DAR particularly the DAR Adjudication Board (DARAB), making them quasi-judicial cases.

• So, RTC has no jurisdiction over agrarian cases EXCEPT: 1. 2.

Cases where the issue is PAYMENT OF JUST COMPENSATION for the property which has been taken under the CARP law. Prosecution of criminal offenses for violation of the CARL.

Quismondo v. Court of Appeals (G.R. No. 95664, September 13, 1991)

Held: In 1980, upon the passage of Batas Pambansa Blg. 129, otherwise known as the Judiciary Reorganization Act, the courts of agrarian relations were integrated into the regional trial courts and the jurisdiction of the former was vested in the latter courts. However, with the enactment of Executive Order No. 229, the regional trial courts were divested of their general jurisdiction to try agrarian reform matters. The said jurisdiction is now vested in the Department of Agrarian Reform. Sections 56 and 57 thereof provide for the designation by the Supreme Court of at least one (1) branch of the regional trial court within each province to act as a special agrarian court. The said special court shall have original and exclusive jurisdiction only over petitions for the determination of just compensation to landowners and the prosecution of criminal offenses under said Act.

Exclusive original jurisdiction 7. In all cases not within the exclusive jurisdiction of any court, tribunal, person or body exercising judicial or quasi-judicial functions • This is called the General Jurisdiction of the RTC • “catch-all” jurisdiction of the RTC

Lupangco v. Court of Appeals (G.R. No. 77372 April 29, 1988)

Facts: Lupangco et al were accounting graduates and reviewing to take the CPA exams in 1985. There were some anomalies in the 1985 CPA Board Examination. By next year, the PRC passed a resolution prohibiting CPA examinees to attend review classes or conferences because of leakages. They are prohibited from receiving any handouts, review materials or any tip from any school, college or university. That was Resolution No. 105 of the PRC. Petitioners Lupangco et al, all CPA reviewers filed an injunction suit against the PRC and to declare the resolution unconstitutional. They filed it with the RTC. The PRC moved to dismiss alleging that the RTC has no jurisdiction over the case because the one which has the jurisdiction is the CA – exclusive jurisdiction to review any decision, order, ruling or- resolution of any quasi-judicial body. Is the PRC correct?

Lupangco v. Court of Appeals (cont’d) Held: No. In order to invoke the exclusive appellate jurisdiction of the Court of Appeals as provided for in Section 9, paragraph 3 of B.P. Blg. 129, there has to be a final order or ruling which resulted from proceedings wherein the administrative body involved exercised its quasi-judicial functions. This does not cover rules and regulations of general applicability issued by the administrative body to implement its purely administrative policies and functions like Resolution No. 105 which was adopted by the respondent PRC as a measure to preserve the integrity of licensure examinations. PRC, in issuing Resolution No. 105, was not acting as a quasi-judicial agency. It was held that the RTC has jurisdiction to entertain Civil Case No. 86-37950 and enjoin the respondent PRC from enforcing its resolution.

Exclusive original jurisdiction 8. Under Section 5.2 of the Securities Regulation Code (R.A. 8799) in relation to Section 5 PD No. 902-A: 1. Controversies involving devices or schemes employed by or any acts, of the board of directors, business associates, its officers or partnership, amounting to fraud and misrepresentation which may be detrimental to the interest of the public and/or of the stockholder, partners, members of associations or organizations registered with the SEC. 2. Controversies arising out of intra-corporate or partnership relations 3. Controversies in the election or appointments of directors, trustees, officers or managers of such corporations, partnerships or associations.

Atwel v. Concepcion

(G.R. No. 169370 April 14, 2008) Held: To determine whether a case involves an intra-corporate controversy to be heard and decided by the RTC, two elements must concur: (1) the status or relationship of the parties and [RELATIONSHIP TEST] (2) the nature of the question that is subject of their controversy. [NATURE OF THE CONTROVERSY TEST] The first element requires that the controversy must arise out of intra-corporate or partnership relations: (a) between any or all of the parties and the corporation, partnership or association of which they are stockholders, members or associates; (b) between any or all of them and the corporation, partnership or association of which they are stockholders, members or associates and (c) between such corporation, partnership or association and the State insofar as it concerns their individual franchises. The second element requires that the dispute among the parties be intrinsically connected with the regulation of the corporation. If the nature of the controversy involves matters that are purely civil in character, necessarily, the case does not involve an intra-corporate controversy.

Concurrent Original Jurisdiction 1. With the SC

• actions affecting ambassadors and other public ministers and consuls

2. With the SC and CA

• Petitions for habeas corpus • Petitions for issuance of writs of certiorari, prohibition, mandamus, quo warranto, habeas corpus, and injunction which may be enforced in any part of their respective regions

3. With the SC, CA and SB

• Petition for issuance of writ of amparo and writ of habeas data

4. With the Insurance Commissioner

• Single insurance claim not exceeding P5 million (see Section 439 of Insurance Code, as amended).

Special jurisdiction of the RTC 8. Section 23 of BP 129: The Supreme Court may designate certain branches of the Regional Trial Courts to handle exclusively criminal cases, juvenile and domestic relations cases, agrarian cases, urban land reform cases which do not fall under the jurisdiction of quasi-judicial bodies and agencies, and/or such other special cases as the Supreme Court may determine in the interest of a speedy and efficient administration of justice. ØSpecial Courts for Drug Cases ØCommercial Courts ØEnvironmental Courts

Appellate Jurisdiction of RTC • Sec. 22 of BP 129: • Appellate jurisdiction. - Regional Trial Courts shall exercise appellate jurisdiction over all cases decided by MetTCs, MTCs and MCTCs in their respective territorial jurisdictions. Such cases shall be decided on the basis of the entire record of the proceedings had in the court of origin and such memoranda and/or briefs as may be submitted by the parties or required by the RTCs. The decision of the RTCs in such cases shall be appealable by petition for review to the CA which may give it due course only when the petition show prima facie that the lower court has committed an error of fact or law that will warrant a reversal or modification of the decision or judgment sought to be reviewed.

Distinguish the original jurisdiction and appellate jurisdiction of the RTC

Family Courts (R.A. No. 8369) • In areas where there are no FCs, the enumerated cases shall be tried with the RTC. • Exclusive Original Jurisdiction: 1. 2. 3. 4.

Criminal cases where one or more of the accused is a minor Petitions for guardianship, custody of children, habeas corpus Petitions for adoption of children and the revocation thereof Complaints for annulment of marriage, declaration of nullity of marriage and those relating to marital status and property relations, and petitions for dissolution of conjugal partnership of gains 5. Petitions for support and/or acknowledgment 6. Summary judicial proceedings under the Family Code 7. Petitions for declaration of status of children as abandoned, dependent or neglected children, petitions for voluntary or involuntary commitment of children; the suspension, termination, or restoration of parental authority 8. Petitions for the constitution of the family home 9. Cases against minors cognizable under the Dangerous Drugs Act 10. Violations of Republic Act No. 7610, 11. VAWC cases

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