Objection-of-jurisdiction-over-subject-matter-grande.docx

Saturnino Salera, Jr, et’al v. A1 Investors G.R. No. 141238. February 15, 2002 Facts: Teodora Salera, mother of the petitioners, contracted a load and issued a promissory note to the respondent A1 Investors, which remained unpaid long after it had fallen due. Hence, respondent filed a complaint for collection of a sum of money against Teodora Salera and her spouse Saturnino Salera, Jr in the Metropolitan Trial Court of Quezon City. The summons was received by the spouses’ son at their family home in Cebu but refused to sign the receipt thereof. Salera , Sr claims that they did not receive the summons that was sent and were not able to file an Answer because they lived in Bohol. The MTCT decided in favor of A1 Investors; copy of such was sent again to the family’s residential address in Cebu, but the spouses were then still residing in Bohol. The spouses did not appeal and the decision became final and executor upon the expiration of the appeal period. A Writ of Execution and a Notice of Levy upon Realty Pursuant to Writ of Execution was sent to Cebu which were received by their daughter who failed to show such to her parents on time. Saturnino, Sr filed a complaint for “injunction with damages” against the respondent followed by a preliminary injunction in RTC Cebu. Salera , Sr died and was replaced by his children. Respondent filed for motion to quash the writ which was denied, hence the latter filed for motion for reconsideration which was also denied. Respondent then filed a petition for certiorari and prohibition with the Court of Appeals which was granted. Petitioners filed for a motion for reconsideration which was denied. Hence, this appeal. Issue: Whether or not the Regional Trial Court Cebu have jurisdiction over the case Held: No, RTC of Cebu did not have jurisdiction over the subject matter of the complaint. Section 10, Rule 47 of the 1997 Rules of Civil Procedure provides that an action to annul a judgment or final order of a MTC shall be filed in the RTC having jurisdiction over the former… It is therefore the RTC of Quezon City which has jurisdiction over a case seeking annulment of the final decision of the MTCT of Quezon City which is similar in rank as the aforementioned Municipal Trial Court.

Bilag v, Ay-ay G. R. No. 189950; April 24, 2017 Facts: Respondents alleged that Bilag sold to them parcels of land, which were registered on a Deeds of Sale and that the latter not only acknowledge full payment and guaranteed that his heirs, or successors-in-interest, and executors are to be bound by such sales by the also caused the subject lands to be removed from the ancestral land claims. Respondents further alleged that they have been in continuous possession of the said land and they have already introduced various improvements thereon. However, the petitioners refused to acknowledge such and continued to harass the respondents. Hence, respondents filed for the instant complaint to quiet their titles and remove the cloud cast upon their ownership. Petitioners filed a Motion to Dismiss on the grounds of lack of jurisdiction, prescription/ laches/ estoppels and res judicata averring that the subject lands were of the public domain and that there was already an injunction case asserting the petitioners ownership over the subject land. RTC ruled in favor of the petitioners. Aggrieved, respondents appealed to the CA which dismissed the RTC’s decision. Petitioners moved for reconsideration which was however denied. Issue: Whether or not CA erred on its decision Held: Yes, CA erred on dismissing the RTC’s decision. Jurisprudence has consistently held that jurisdiction is defined as the power and authority of a court to hear, try, and decide a case. Thus, when a court has no jurisdiction over the matter, the only power it has is to dismiss the action. A judgment rendered by a court without jurisdiction is therefor null and void. The subject lands are untitled and unregistered public land, hence, petitioners correctly argued that it is the Director of Lands who has the authority to award their ownership. Thus the RTC correctly recognized its lack of power to hear and resolve respondents’ action. In this light, the decision of CA should be reversed.

Mangubat v. Morga- Serva G.R. No. 202611; November 23, 2015 Facts: Spouses Mangubat filed with the Regional Trial Court of Pili, Camarines Sur a Complaint for Specific Performance with Damages against respondent Morga-Serva and two other defendants. The RTC on 1985,ruled in favor of the plaintiffs and such became final and executory . On 1998, Gaudencio Mangubat and his children as heirs of the deceased Aurelia Mangubat filed with the same court a complaint for revival of the decision. The averred that the decision could not be implemented because the defendants evaded the service thereof and since five years had already lapsed form the date of its entry, the former prayed for the revival. Both parties enter into a compromise agreement, that upon payment by the plaintiff the latter may recover her formerly owned lot, which was approved by the RTC. Morga- Serva then handed her payment, however, she alleged that the heirs refused to convey the title of the lot. Abner filed a motion to declare the amicable settlement null and void alleging that his father acted only on his own behalf when he entered into the agreement., but it was denied, as well as the motion for reconsideration. Abner filed a petition forr annulment of final order with the CA contending the Belen paid beyond the period stipulated int the compromise agreement, thus the RTC’s ruling was unjust. CA dismissed the petition for lach of merit. The Motion for reconsideration was likewise denied. Hence, petitioner filed for review on certiorari. Issue: Whether or not the RTC lost its jurisdiction when its decision as to the compromise agreement became final and executory. Held: No. Jurisdiction over the nature of the action or subject matter is conferred by law. The RTC's jurisdiction over petitions for revival of judgment had already been upheld by the Court. It was held that "an action for revival of judgment may be filed either 'in the same court where said judgment was rendered or in the place where the plaintiff or defendant resides, or in any other place designated by the statutes which treat of the venue of actions in general. Here, the Complaint for revival of judgment was filed in the same court. Undoubtedly, the RTC has jurisdiction over the action. There is therefore no valid ground for the Petition for Annulment of Final Order that Abner filed with the CA.

Saint Louis University v. Cordero G.R. No. 144118; July 21, 2004 Facts:

Corderos filed a complaint for damages against SLU and several officials which was anchored on gross negligence on the part of the defendants resulting in the infliction of injuries on Winston, Corderos’ child. RTC found the petitioners guilty of gross negligence. Corderos filed a Motion for Reconsideration asking the trial court to increase the amount of damages awarded to Winston and to include an award to them. PEtitoners filed a Notice of Appeal and opposed the MR for having been filed out of time. RTC acting on different judge, granted the MR. Petitioners then filed their notice of appeal with the trial court. While noting that the docket fees and other lawful fees had not been paid, the trial court nevertheless ruled that the petitioners had filed the notice of appeal on time. It ordered the entire records of the case to be forwarded to the Court of Appeals. Petitioners filed a motion to admit docket and filing fees to CA, accompanied by two postal money To explain the delay, petitioners counsel stated that he did not know the amount to be paid or the manner in which to pay it. but it was denied. Their MR was likewise denied. Issue: Whether or not the dismissal by the Court of Appeals of the appeal was proper when it relied upon the failure of petitioners to abide by the procedural rule regarding the payment of docket fees Held: The general rule is that the payment of docket fees within the prescribed period is mandatory for the perfection of an appeal. Settled is the rule that the perfection of an appeal within the reglementary period and in the manner prescribed by law is jurisdictional, and noncompliance with such legal requirement is fatal. Without such payment, the appellate court does not acquire jurisdiction over the subject matter of the action and the decision sought to be appealed from becomes final and executory. In view of petitioners failure to pay the docket fees on time and in the manner mandated by the Rules of Court, their appeal cannot be deemed perfected. The appealed decision, therefore, has become final and executory.

Republic of the Philippines v. Bantigue Point Development Corp., G.R. No. 162322; March 14, 2012 Facts: Petitioner assails the decision of the CA which affirmed the Decision of the MTC of San Juan, Batangas granting the respondent application for original registration of a parcel of land; CA ruled that since the former had actively participated in the proceedings before the lower court, but failed to raise the jurisdictional challenge therein, petitioner is thereby estopped from questioning the jurisdiction of the lower court on appeal. Issue: Whether or not the petitioner Republic is stopped f rom raising the issue of jurisdiction Held: No. Petitioner Republic is not estopped from questioning the jurisdiction of the lower court, even if the former raised the jurisdictional question only on appeal. The rule is settled that lack of jurisdiction over the subject matter may be raised at any stage of the proceedings. Jurisdiction over the subject matter is conferred only by the Constitution or the law. It cannot be acquired through a waiver or enlarged by the omission of the parties or conferred by the acquiescence of the court. Consequently, questions of jurisdiction may be cognizable even if raised for the first time on appeal. In this case, petitioner Republic has not displayed such unreasonable failure or neglect that would lead us to conclude that it has abandoned or declined to assert its right to question the lower court's jurisdiction.