The 1997 Rules of Civil Procedure Jurisdiction of the

2000 Edition < DRAFT COPY; Pls. check for errors > Regional Trial Courts

JURISDICTION OF THE
REGIONAL TRIAL COURTS

Ito ang third level, ‘no? And by going over their jurisdiction, you will see that it is a court of
general jurisdiction and it is actually the workforce of the whole judiciary. ‘Yan…talagang mabigat
ang trabaho nitong RTC. Their workload is terrible. Before, somebody asked me, “Dean, gusto
mong mag-judge sa RTC?” Inyuha na na! (Burawi nyo!) Inyo na nang trabaho na ‘yan because there
are 2 things there when you get the job of the RTC judge: Of course, you want to excel, you want to
do your job properly and efficiently, you will die early because of the workload. Or, you end up as
one who is lazy. You end up with administrative cases for laziness, left and right. So mabuti pa,
huwag ka na lang magtrabaho diyan, kasi mabigat ang trabaho diyan.

Q: How many RTC’s are there in the Philippines, from Northern Luzon to Southern Mindanao?
In your opinion?
A: You look at the opening clause of Section 13:

Section 13 (1) Creation of Regional Trial Courts – There are hereby

created thirteen (13) Regional Trial Courts, one for each of the following
regions: x x

So the Judiciary law has divided the country into 13 areas which is called JUDICIAL REGION.
From the 1st to the 12th, the 13th is actually in the National Capital Region (NCR), Metro Manila.
Every division is divided into branches and the number of branches keep on increasing by law.

So, to what region do we belong? We are in the 11th judicial region. So there is one RTC for the
11th judicial region, pero bakit ‘yun ganoon? Davao City lang, more than 10 na? Well, here is
where you will go back to your fundamentals. A court is not the same as a judge. ‘Yan…

Actually, what the law says is that, there are 13 RTCs, and every court is divided into branches.
So, kung branches siguro, malapit nang maging 1000 throughout the country. So there are 13
courts with almost 1000 judges. Now, as a matter of fact, if you want to know exactly how many
there are, you refer to your Section 14. Actually, this has been amended many times because from
1980 up to the present, Congress passed laws. In fact when the law took effect, according to Section
14, there are originally 29 RTC judges commissioned for the 11th judicial region – 29 originally.

Now, from what I know, based on the amendment in 1991, it was increased from 29 to 41. So
there are supposed to be 41 RTC judges for the 11th judicial region. As I said, unless from 1991 to
the present dinagdagan na naman nila.

So 41 RTC judges shall be commissioned for the 11th judicial region. There should be 6
branches which sits thereafter for the province of Davao del Norte, which sits at Tagum,
Nabunturan and Panabo. Four branches which sit thereat for the province of Davao Oriental which
sits at Mati, Bagangga and Butuan. Sixteen branches which sit thereat for the province of Davao del
Sur. And the City of Davao which sits at Davao City, Digos, Malita and Bansalan. Then 10
branches whish sit thereat for the province of South Cotabato and the City of General Santos which
sit at General Santos City, Koronadal [the City of Eumir, Francis and Mortz], Surallah, and
Polomolok. And 5 branches which sit thereat for the province of Surigao del Sur which sit at
Tandag, Ginanga, Bislig and Kantilan. So that is how they are distributed within the 11th the
juridical region.

Q: So, since there are 41 of them scattered throughout the 11th judicial region, from Surigao to
South Cotabato, for example, I would like to file a case against my neighbor based in Davao. So i-
file ko sa Polomolok, anyway that’s the same court, eh. Or a criminal in Davao City file-an sa Mati.
Anyway, the same court na. Are you allowed to do that?

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A. The answer is NO! Every branch of the RTC has its own area of responsibility. Except in
Davao City, or in chartered cities, the authority of every branch here is throughout Davao City. But
sa probinsya, hati-hati ‘yan eh, and the provision there is Section 18 of BP 129.

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.

‘Yan, so in the province every branch has its own defined area. So, for example if you are from
Nabunturan, you cannot file a case in Panabo. Kalayo-layo niyan. There is a branch there in
Nabunturan. Doon ka mag-file. Kanya-kanya ng responsibility.

Now, the law says, the SC has the power to define the area of its branch for purposes of
supervising that area and the MTC there. Now, as early as 1983, the SC has already come out with
administrative order throughout the Philippines defining the area of responsibility of each branch.
Sometimes I need that, eh, because there are cases to be filed outside Davao City, especially
Cotabato Province. And you have to be updated kung sang branch ba ako pupunta nito.
Sometimes you have a hard time, eh. For example, the case originated in Babak, part of Davao del
Norte, saan ba ito i-file? Panabo or Tagum? I need to consult that circular. ‘Yan…that will be very
helpful. Now you please correlate Section 18 of the Judiciary Law with the Interim Rules Section 2
because Section 2 of the Interim Rules is related to this, eh.

Interim Rules, Sec. 2. Territorial Jurisdiction of Courts. -

a) MetTCs, MTCs and MCTCs shall exercise their jurisdiction in the city,
municipality or circuit for which the judge thereof is appointed or
designated.
b) A Regional Trial Court shall exercise its jurisdiction within the
area defined by the SC as the territory over which the particular branch
concerned shall exercise its authority, in accordance with Sec. 18 of BP
129.

Yaan! So every RTC shall have authority. Alright, these are what you call administrative
provisions.

Now, let’s go to the jurisdiction of the RTC:

EXCLUSIVE ORIGINAL JURISDICTION– Section 19 as amended by RA 7691

CONCURRENT ORIGINAL JURISDICTION with other courts – Section 21
APPELLATE JURISDICTION – Section 22

EXCLUSIVE ORIGINAL JURISDICTION OF THE RTC

Sec. 19 Jurisdiction in civil cases – Regional Trial Courts shall

exercise exclusive original jurisdiction:

[1] In all civil actions in which the subject of the litigation is

incapable of pecuniary estimation.

What does it mean? When the subject of the litigation is not expressed in terms of pesos,
centavos. Alright.

In most cases that we know, the demand of the plaintiff is expressed in terms of amount, eh.
EXAMPLE: A creditor will file a case for the collection of the unpaid loan from the defendant. Ang
nakalagay sa demanda niya, that after trial that the court should order the defendant to pay him the

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sum of P500,000 na utang with interest. So, the subject is expressed in terms of amount of damages
ba, the court shall award to the defendant damages amounting to half a million. Karamihan ng kaso
ganyan.

But here, in this civil case, the subject of the civil case is not capable of pecuniary estimation. It
cannot be estimated or calculated in pesos.

EXAMPLE is an action for annulment; rescission of contract; an action for specific performance;
an action for declaratory relief by express provision of the law now; an action for the permanent
injunction against somebody;

[2] In all civil actions which involve the title to, or possession of,
real property or any interest therein, where the assessed value of the
property involved exceeds P20,000 or for civil actions in Metro Manila,
where such value exceeds P50,000 except actions for forcible entry into and
unlawful detainer of lands and buildings; original jurisdiction over which
is conferred upon the Metropolitan Trial Courts, Municipal Circuit Trial
Courts;

So real actions outside of forcible entry and unlawful detainer. The best example would be
accion publiciana, accion reinvidicatoria, quieting of title, provided the value of the property
exceeds P20,000.00 based on the assessed value of the property.

So, for a lesser value, MTC has jurisdiction. This is why MTCs now has jurisdiction over accion
publiciana when the value of the property is P20,000 or less. But kung forcible entry and unlawful
detainer, klaro yan – walang RTC.

Now, if in Metro Manila, then value is P50,000. But outside Metro Manila, the assessed value is
only P20,000.

[3] In all civil actions in admiralty and maritime jurisdiction where the
demand or claim exceeds One Hundred Thousand pesos (P100,00.00) [now PhP
200,000.00] or, in Metro Manila, where such demand or claim exceeds Two
Hundred Thousand pesos (P200,000.00)[now, PhP 400,000].

EXAMPLE: The shipper will ship to you in Davao goods involving common carrier. While in
transit, the goods are lost or they are totally damaged. You would like to file a claim or a case
against the carrier, what kind of a case? That is an admiralty or maritime case.

Q: If you are going to file a case against the shipping company, where will you file it? RTC or
MTC?
A: It depends on how much is your claim. If your claim of the damaged or lost cargo exceeds
P200,000, sa RTC; if it is P200,000 or less, sa MTC. In Metro Manila, the jurisdiction is higher – it
should be over P400,000. Now do not confuse this with No. 2 because that involves LAND with
more than P20,000 value.

Take note that prior to August 16, 1999, the claim should exceed P100,000 or P200,000 in Metro
Manila as the case may be. Now, the claim is adjusted to P200,000 and P400,000, respectively
pursuant to Section 5 of RA 7691 which took effect last August 15, 1995:

RA 7691, Sec. 5. After five (5) years from the effectivity of this Act,
the jurisdictional amounts mentioned in Sec. 19(3), (4), and (8); and Sec.
33(1) of Batas Pambansa Blg. 129 as amended by this Act, shall be adjusted
to Two hundred thousand pesos (P200,000.00). Five (5) years thereafter,
such jurisdictional amounts shall be adjusted further to Three hundred
thousand pesos (P300,000.00): Provided, however, That in the case of Metro
Manila, the abovementioned jurisdictional amounts shall be adjusted after
five (5) years from the effectivity of this Act to Four hundred thousand
pesos (P400,000,00).

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So after August 16, 1999 (5 years from the effectivity of RA 7691) yung P100,000.00 naging
P200,000 na. Yung P200,000 in Metro Manila, naging P400,000. Then after another 5 years (2004),
aakyat na naman ang jurisdiction ng MTC. So from the original P100,000.00 magiging P300,000 na
yan. Automatic ha.

[4] In all matters of probate, both estate and intestate, where the gross
value of the estate exceeds One Hundred Thousand pesos (P100,000.00) [now
P200,000] or, in probate matters in Metro Manila, where such gross value
exceeds Two Hundred Thousand pesos (P200,000.00) [now P400,000].

In the subject of Wills and Succession, when a person dies, his estate, his property will be settled
for the benefit of his creditors and heirs. That is what you call either as testate or intestate
proceedings depending on whether the deceased left a will or none.
Q: Where should the estate of the deceased person be settled, RTC or MTC?
A: It depends on how much is the gross value of his estate. If it exceeds P200,000, RTC. If it is
P200,000 or less, it should be with the MTC. In Metro Manila again, it is doubled, the gross should
be more than P400,000. And again, this will automatically increase after 5 years from 1999.

[5] In all actions involving the contract of marriage and marital

relations.

Most of these cases are under the Family Code.

Q: What are the possible actions which you can imagine involve the contract of marriage and
marital relations?
A: Annulment of marriage, legal separation, declaration of nullity, dissolution of the absolute
community of husband and wife, and action for support. These cases are the ones arising under the
Family Code, where it arises out of a marital relationship.

Take note that these cases are NO LONGER covered by the RTC because under RA 8369
(Family Courts Act of 1997), these cases should now be tried by the FAMILY COURTS.

RA 8369, SECTION 5. Jurisdiction of Family Courts. — The Family Courts

shall have exclusive original jurisdiction to hear and decide the following
cases:
x x x x x x
d) Complaints for annulment of marriage, declaration of nullity of
marriage and those relating to marital status and property relations of
husband and wife or those living together under different status and
agreements, and petitions for dissolution of conjugal partnership of gains;
x x x x x x

Now, in areas where there are no family courts, the cases shall be adjudicated by the RTC. So
certain branches of the RTC will act as family courts (acting family courts.

We shall skip first no. 6. We will return to that later. Let’s go to no. 7.

[7] In all civil actions and special proceedings falling within the
exclusive original jurisdiction of a Juvenile and Domestic Relations Court
and of the Court of Agrarian Relations as now provided by law;

Before BP 129, these were special courts existing before 1980. Among these courts were the so
called Juvenile and Domestic Relations Courts (JDRC). Then you have the Court of Agrarian
Relations (CAR) which tried the cases involving tenancy, agricultural lessor, agricultural lessee,
agricultural lands. When BP 129 was enacted, the CAR and the JDRCs were abolished. Cases
which they used to handle were automatically transferred to the RTC. That was after BP 129 took
effect.

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What were the cases which were usually falling within the original jurisdiction of the former
JDRC? Usually, those involving family and children, like support filed by the child against his
father, compulsory recognition, custody of children, adoption proceedings – these are the cases
which are usually heard by the JDRC.

Under BP 129, all of these are now within the jurisdiction of RTC. HOWEVER, this has been
amended again by RA 8369 (Family Courts Act of 1997) These cases are now under the jurisdiction
of the FAMILY COURTS: (See Sections 5 [b], [c], [e], [g])

RA 8369, SECTION 5. Jurisdiction of Family Courts. — The Family Courts

shall have exclusive original jurisdiction to hear and decide the following
cases:
x x x x
b) Petitions for guardianship, custody of children, habeas corpus in
relation to the latter;
c) Petitions for adoption of children and the revocation thereof;
x x x x
g) 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 and other cases cognizable under Presidential Decree No.
603, Executive Order No. 56, (Series of 1986), and other related laws;
x x x x x

But the law transferring the jurisdiction of the CAR to the RTC became partially obsolete with
the enactment of the Comprehensive Agrarian Reform Law (CARL) or RA 6657 (June 15, 1988).
Under the CARL, 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, from CAR to RTC, from RTC to DARAB

So the RTC has NO jurisdiction, EXCEPT in the following 2 cases:

1.) Cases where the issue is PAYMENT OF JUST COMPENSATION, f or, the property which
has been taken under CARP law;

EXAMPLE: If you are a landowner and your agricultural land is placed under the
CARP coverage, the government will fix the payment for you. The trouble is that you
did not lot agree on the amount of payment. Agrabiyado ka sa compensation ng
gobyerno. Now, you go to RTC and you ask for higher compensation.

1.) Prosecution of criminal offenses for violation of the CARL;

So these are the only agrarian cases which still belongs to the RTC. This was explained by the
SC in the case of

QUISMUNDO vs. COURT OF APPEALS

201 SCRA 609 [1991]

HELD: “Wth the enactment of Executive Order No. 229, which took effect on
August 29, 1987, 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. Said provisions thus delimit the jurisdiction of the regional trial
courts in agrarian cases only to two instances:
1.) petitions for the determination of just compensation to landowners; and
2.) prosecution of criminal offenses under said Act.

[8] In all cases in which the demand, exclusive of interest, damages of

whatever kind, attorney’s fees, litigation expenses, and costs or the value
of the property in controversy exceeds One Hundred Thousand pesos
(P100,000.00) [now P200,000] or, in such other cases in Metro Manila, where

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the demand, exclusive of the above-mentioned items exceeds Two Hundred

Thousand pesos (P200,000.00)[now P400,000]

The best example is money claim. Most cases which go to court now are money claims – an
action to collect sum of money.

Q: Unpaid loan – you would like to collect an unpaid loan of your debtor. Where will you file
your case?
A: It depends on how much are you collecting. If it is over P200,000 outside Metro Manila –
RTC, in Metro Manila, double the amount – P400,000. If the amount that you are collecting is only
P200,000 or less obviously, you file your case in the MTC.

If the value of the claim is > P200,000 – RTC

If the value of the claim is = or < P200,000 – MTC

So this is the same as number [3] and [4] where the jurisdiction of the MTC was raised from
P20,000 to P100,000. And under the present law, it is now P200,000. But again, this is subject to the
automatic increase in jurisdiction by 2004.

Q: Suppose the principal amount that you borrowed from me is P200,000, the interest is P30,000.
And you are collecting P10,000 for moral damages, another P10,000 for expense of litigation, etc. So
my total claim is P250,000. Where will I file the case?
A: MTC pa rin. In determining the jurisdictional limit of P200,000, do not include the interest,
damages, attorney’s fees, etc. So you deduct those from the principal claim even if you put them in
your complaint because the law says, “xxx exclusive of interest, damages of whatever kind,
attorney’s fees, litigation expenses, and costs xxx.”

Q: What are litigation expenses and costs?

A: Costs are not the same as attorney’s fees and litigation expenses. Actually, attorney’s fees and
litigation expenses are part of damages. Costs are governed by Rule 141, while attorney’s fees and
litigation expenses are governed by the Civil Code. Because there is some confusion there, akala
ang costs and litigation expense, pareho. No, they are not the same.

ACTIONS PURELY FOR DAMAGES

SITUATION: Suppose the action is purely for damages, like breach of contract of carriage.
Instead of bringing you to your destination, you ended up in the hospital. You now sue the
common carrier for damages and your claim is P1 million for injuries, moral, exemplary, etc. Now,
because the law says the jurisdiction of the RTC is above P200,000 but do not include damages. The
claim in this case is P1 million, all for damages. Now, where will you file the case?

Somebody said it should be in the MTC because in determining the jurisdiction of the RTC, you
do not include damages. If that is the interpretation, I said, all damage suits cannot be tried by the
RTC because remember, you pay filing fee for these cases but the jurisdiction is limited to the MTC.
That is absurd! I do not believe that kung puro damages wala ng jurisdiction ang RTC. Otherwise,
all damage suits should be filed in the MTC.

This question has been clarified by SC Circular No. 09-94: “Guidelines in the Implementation of
RA 7691 Extending the Jurisdiction of the MTCs” where the SC said that the provision excluding
damages applies only if the damages are INCIDENTAL to the action. If the main cause of action is
100% damages, you include it in determining tire P200,000 jurisdictional limit of the MTC.

EXAMPLE: Ms. Pastor rode on a PAL fight. The plane crashed but she survived. She claims for
damages for breach of contract of carriage amounting to P1 million.
Q: Where will she file her case?
A: RTC because the amount of the claim for damages exceeded P200,000. Since the case is
purely for damages, it is included in determining the jurisdiction of the court.

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The rule is, you only exclude the damages if it is a secondary claim. But if damages is the
primary or only claim, you determine whether the total claim for damages is above P200,000, or
equal to or less than P200,000. Yaaann!

The SC said in this Circular, “the exclusive damages of whatever kind” in determining the
jurisdiction under Section 19 paragraph [8] applies to cases where the damages are merely
incidental to or a consequence of the main cause of action. However, if the claim for damages is the
main cause of action, the amount of such claim should be considered in determining the
jurisdiction.

EXAMPLE: Inay will file a case against Janis to recover a piece of land worth P20,000.00 only.
But her claim for damages exceeds P300,000. So, you will notice ang claim for damages is incidental
lang. Ang main action is to recover a piece of land.
Q: In what court will Inay file a civil case where she wants to recover a piece of land with value
of only P20,000?
A: MTC because of paragraph [2]. But ang damages naman is P300,000? MTC pa rin iyan
because such damages, being incidental, is not included in determining the jurisdiction of the RTC.

However, if my actions against you is purely damages, like I will file a case against you for
damages arising from vehicular collision and I will claim P300,000 for damages, it should be in the
RTC. That is the explanation. The term “excluding damages” applies only if the damages are purely
incidental to the case. But if the action is purely damages, then you observe the P200,000
jurisdictional limit.

Now, the law says, “exclusive of interest, damages of whatever kind, attorney’s fees, litigation
expenses, and costs or THE VALUE OF THE PROPERTY IN CONTROVERSY exceeds P200,000….”

Q: What is the property in controversy?

A: Obviously here, the property is PERSONAL PROPERTY not real. If the property sought to be
recovered is real, apply paragraph [2] of Section 19 on recovery of real property.

Q: In the subject of Sales, the unpaid seller would like to rescind the sale and get back the unit.
Where will the unpaid seller file the case?
A: If above P200,000 sa RTC ka. It if is only P200,000 or less, sa MTC. So this is an example of
“the value of the [personal] property in controversy.”

Q: (By a classmate, Review class) Who shall determine the value or how should the value be
determined?
A: You will learn the answer when we reach Rule 16 on Motion to Dismiss. In determining the
jurisdiction of the court, in the meantime, which will prevail? You will learn later that the
allegations of the complaint will prevail.

Like for example, I will file a case against you for an unpaid loan of P250,000. Then you say in
your motion to dismiss, “No! ang utang ko sa iyo is not P150,000, but only P80,000. Therefore, the
RTC has no jurisdiction.” So there is now a conflict with what I’m saying and with what you are
saying.

With that, we will discuss the conflict later. Now, we do not know who is telling the truth. For
the moment, the rule is, you follow the plaintiff because jurisdiction is determined by the
allegations of the complaint. It is the complaint which will determined whether the court has
jurisdiction over the subject matter. It is not based on what the defendant is saying. That is the
answer there.

Let us go to some interesting cases on this provision.

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ORTIGAS AND CO., LTD PARTNERSHIP vs. HERRERA

120 SCRA 89 [1983]

FACTS: A entered into an agreement with B where A deposited the sum of P50,000
with B. After certain conditions are complied B has to return the amount to A.
According to A the conditions are already complied with but B still refuses to return the
money. So A filed a complaint which he denominated as sum of money and since he is
only asking for the return of P50,000, A filed the case in the MTC.

ISSUE #1: Whether or note the MTC has jurisdiction over the case.
HELD: The MTC has NO jurisdiction. It should be filed in the RTC. It is not an action
to collect a loan. You are not recovering a loan. You are compelling him to comply with
the agreement – to return the money after certain condition are complied with, di ba?
You are trying to enforce your agreement. therefore your action is an action for
SPECIFIC PERFORMANCE which should be tried by the RTC under paragraph [1].
“When a party to a contract has agreed to refund to the other party a sum of money
upon compliance by the latter of certain conditions and only upon compliance therewith
may what is legally due him under the written contract be demanded, the action is one
not capable of pecuniary estimation.” So it is cognizable by the RTC.

ISSUE #2: But according to the plaintiff, when he filed the complaint, it is entitled
“for sum of money” which should fall under paragraph [8]. Is the plaintiff correct?
HELD: NO. The plaintiff is wrong. The title of the action is not determinative of the
court. Just like the rule on contracts where the nature of the contract is not determined
by the title but by stipulation.
“The factual allegations in the complaint seeking for the performance of an
obligation of a written contract which is a matter clearly incapable of pecuniary
estimation prevail over the designation of the complaint as one for the sum of money
and damages.”

[6] In all cases not within the exclusive jurisdiction of any court,
tribunal, person or body exercising judicial or quasi-judicial functions

Practically, this makes the RTC the universal catcher – what does not belong to anyone of you,
belongs to me. That’s what this provision is saying.

EXAMPLE: An employee, Inday Locsin, files a case against the employer, Kenneth Lim, to
claim non-payment of wages, overtime pay, ECOLA and reinstatement for illegal termination.
Under the Labor Code, dapat sa NLRC. So it does not belong to RTC but if there is no vesting to
NLRC, then it goes to the RTC.

A case which does not belong to any other court. Let’s try to connect it with something you
know.

Q: If you want to file an action for annulment of judgment of RTC, where will you file your
action?
A: CA only – an exclusive original jurisdiction of the action for annulment of the judgment of
the RTC.

Q: Suppose Karen will file an action for annulment of judgment of the MTC. Does it belong to
the CA?
A: NO! What the law says is: annulment of judgment of RTC, and not MTC. How about
Supreme Court? Lalong wala. Saan ka pupunta? There is really no provision in BP 129 which goes
that way. I don’t think you can go to NLRC.

Wala kang mapuntahan, saan ka tatakbo? Sa RTC because it does not belong to the jurisdiction
of any other court. It should fall under paragraph [6] That is why, this, there are problems reaching

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the SC on jurisdiction – whether a case belongs to this, to the regular court or to a special quasi-
judicial body. And we are going to go over some of these cases.

SANDOVAL vs. CANEBA

190 SCRA 77 [1990]

FACTS: The quarrel in this case involves the owner of the subdivision and the buyer.
Later on, the buyer refused to pay the unpaid installments. The subdivision developer
filed a case for the collection of unpaid installments over the subdivision lots. Now, if
you look at the law, parang money claims sa RTC or MTC.

HELD: The regular courts have no jurisdiction. That should be decided by the
Housing and Land Use Regulatory Board (HLURB) formerly known as NHA. Under PD
957, it is the HLURB not the RTC or MTC which has the jurisdiction to hear a case
involving non-payment of installments over subdivision lots.

The counterpart of this case was the case of

CT TORRES ENTERPRISES, INC. vs. HIBIONADA

191 SCRA 268 [1990]

FACTS: This is also the case between the buyers of a subdivision lot against the
subdivision developer. Only this time baliktad – it is the subdivision lot buyers who are
suing the developer of the subdivision. The subdivision lot owners filed against the
subdivision developer for not maintaining properly the roads of the subdivision. So they
filed a case for specific performance with damages to compel the developer to comply
with the contract to maintain the roads.

HELD: The jurisdiction is with the HLURB and not with the regular courts. But
according to the plaintiff “But I’m also claiming for damages so that it should be filed before
the regular courts. How can the HLURB award damages? Only the regular courts can award the
damages.” Can the HLURB award damages? According to the SC:
“The argument that only courts of justice can adjudicate claims resoluble under the
provisions of the Civil Code is out of step with the fast-changing times. There are
hundreds of administrative bodies now performing this function by virtue of a valid
authorization from the legislature. This quasi-judicial function, as it is called, is exercised
by them as an incident of the principal power entrusted to them of regulating certain
activities falling under their particular expertise.”
So quasi-judicial bodies are now authorized to award damages.

As a matter of fact in Labor Relations, the question is asked whether the NLRC is authorized to
grant damages also to an employee, moral and exemplary, which normally is only awarded by
courts. The Labor Code says yes. In other words, even damages now can be awarded by
administrative bodies such as NLRC.

FAJARDO vs. BAUTISTA

232 SCRA 291 [1994]

FACTS: Isabelo and Marita Jareno and the owners and developers of a subdivision.
Fajardo and others, as buyers, signed separate contracts each designated a contract to
sell under which for consideration therein stated, the Jarenos bound themselves to sell to
Fajardo et al the of subject thereof, and after the latter shall have paid the purchase price
and interest shall execute in favor of Fajardo et al the corresponding deeds of sale.
When these contracts to sell are still ongoing the Jarenos sold these lots to other
buyers and the title was transferred to the second buyer. So when Fajardo et al learned

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about it, they filed separate complaints with the RTC for annulment of the sale to the
other buyers.
Now, according to Fajardo, the jurisdiction of the case belongs to the RTC and not
with the HLURB because the title of the lots are transferred to the other buyers. It is no
longer under the name of Jareno. Secondly, their action is for the annulment of title to a
third person. Thirdly, these third persons are not the developers; fourthly, under the
Judiciary Law, actions involving title to a real property are to be tried by the RTC.

HELD: The RTC still has NO jurisdiction because the case involved unsound real
estate business practice on the part of the subdivision owners and developers. Under the
law, unsound real estate business practice is under the HLURB. The practice in the case
is not a sound real estate business – I am a developer, I enter into a contract with you
and then later on I sold the contract to a third person, that is unsound!
“By virtue of P.D. 1344, the HLURB has the exclusive jurisdiction to hear and decide
the matter. In addition to involving unsound real estate business practices, the
complaints also involve specific performance of the contractual and statutory obligations
of the owners or developers of the subdivision.” So it is still with the HLURB and not
with the regular courts.

BENGUET CORPORATION vs. LEVISTE

204 SCRA 99 [1991]

FACTS: A mining company entered into a operations agreement for management

with another mining company. Then later on, one wants to file a case for rescission of
the agreement for one reason or another. So it was filed with the RTC.

HELD: The RTC has NO jurisdiction again because PD 1281 vested with the Bureau
of Mines with jurisdictional supervision and control over all issues on mining claims
and that the Bureau of Mines shall have the original exclusive jurisdiction to hear and
decide cases involving the cancellation and enforcement of mining contracts.

The trend is to make the adjudication of mining cases a purely administrative matter. Another
case is the case of

MACHETE vs. COURT OF APPEALS

250 SCRA 176 [1995]

FACTS: This case involves the collection by the landowner of unpaid back rentals
from his leasehold tenants. The landowner filed the money claims before the RTC.

HELD: The RTC has no jurisdiction over cases for collection of back rentals for the
leasehold tenants. This is an agrarian dispute which exclusively cognizable by the
DARAB.
“The failure of petitioners to pay back rentals pursuant to the leasehold contract with
landowner is an issue which is clearly beyond the legal competence of the trial court to
resolve. The doctrine of primary jurisdiction does not warrant a court to arrogate unto
itself the authority to resolve a controversy the jurisdiction over which is initially lodged
with an administrative body of special competence.”

Let’s go to Professional Regulation Commission (PRC). That is the government body which
administers all government examination for professionals except members of the law profession.
Sa medicine, CPA, engineer, lahat andiyan sa kanila, including plumber and marine officers. Basta
lahat ng merong examination sa kanila yan except sa bar which is under the jurisdiction of the SC.
Now, this is what happened in the case of

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LUPANGCO ET AL vs. COURT OF APPEALS

160 SCRA 848 [1988]

FACTS: Lupangco et al were BS Accounting graduates and reviewing to take the

CPA exams in 1985.
There were some anomalies (leakages) 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.
So 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. And the PRC is a quasi-judicial
body. So their resolution can only be questioned before the CA and not with the RTC.

HELD: The PRC is WRONG because PRC is not only a quasi-judicial body, it is also
a quasi-legislative body. It also acts as legislative body by issuing rules and regulations.
Now, what kind of resolution is being questioned here? It is a resolution pursuant to
it purely administrative function. It is a measure to preserve the integrity of licensure
examination. Therefore, it does not belong to the CA. It is not the type of resolution
contemplated by Section 9.
“The authority of the CA to review all resolutions of all quasi-judicial bodies
pursuant to the law 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 PRC as a measure to
preserve the integrity of licensure examinations.” So that is not the resolution
reviewable by the CA.
Now, under what provision under Section 19 can we justify the jurisdiction of the
RTC in the case. The SC said: It is under paragraph 1 where the case is incapable of
pecuniary estimation or, it may fall under paragraph 6 where the case is not within the
exclusive jurisdiction by any court, tribunal or- body exercising Judicial or quasi-judicial
functions.

So, if it is not reviewable by the CA, in what court can you question the resolution? Definitely,
not the CA, definitely not the SC. I don’t think it’s with the NLRC. So it will fall under the
jurisdiction of the RTC. Or, it can also fall under paragraph [1,] where the subject matter of the suit
is not capable of pecuniary estimation because what is the nature of the demands is to declare
unconstitutional this resolution. So it belongs to the jurisdiction of the RTC.

BERNARDO vs. CALTEX PHIL. INC.

216 SCRA 170 [1992]

FACTS: Under E.O. No. 172, when there is a dispute between an operator or dealer
and an Oil company regarding dealership agreement, the case shall be under the
jurisdiction of the Energy Regulatory Board (ERB). So any dispute regarding their
relationship agreement except disputes arising out of the relationship as debtor and
creditor. So if the dispute arose out of the relationship as bebtor and creditor, it should
be filed with the RTC.
Now what happened here is that on December 5, 1990, Bernardo, a dealer of Caltex,
ordered gasoline from Caltex. So he ordered in the morning. At 6:00 at night on the same
day, there was a price increase. So when the gasoline was delivered the following day,
Caltex charged Bernardo for the increased price. Bernardo refused to pay and he he filed
a case before the RTC. Caltex argued that the case should be filed with the ERB.

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HELD: The RTC has jurisdiction because “a contract of sale of petroleum products
was here perfected between Caltex and its operator/dealer Bernardo; that in virtue of
the payment admittedly made by Bernardo, Caltex became a “debtor” to him in the
sense that it was obligated to make delivery to Bernardo of the petroleum products
ordered by him; and that the only issue is the manner by which Caltex shall perform its
commitment in Bernardo’s favor. It is rather one cognizable by the Regional Trial Court,
as a dispute indeed ‘arising out of their relationship as debtor and creditor.’”
“What the controversy is all about, to repeat, is simply the prices at which the
petroleum products shall be deemed to have been purchased from Caltex by Bernardo
in December 5, 1990. This is obviously a civil law question, one determinable according
to the provisions of the Civil Code and hence, beyond the cognizance of the Energy
Regulatory Board.”

CONCURRENT ORIGINAL JURISDICTION OF THE RTC

Sec. 21. Original jurisdiction in other cases. - Regional Trial Courts

shall exercise original jurisdiction:

[1] In the issuance of writs of certiorari, prohibition, mandamus, quo

warranto, habeas corpus, and injunction which may be enforced in any part of
their respective regions;

Q: What is the difference between the original jurisdiction of the RTC in Section 21 and the
original jurisdiction of the RTC in Section 19?
A: In Section 19, you have the EXCLUSIVE original jurisdiction, whereas in Section 21 you have
the original jurisdiction but CONCURRENT with other courts.

Thus “original” jurisdiction stated in Section 21 is also shared with the SC and CA. Therefore ,
the SC, CA, and RTC have original concurrent jurisdiction under Section 21. Like issuance of writs
of certiorari, prohibition, mandamus, quo warranto, habeas corpus, etc. This is concurrent with the
CA and the SC. Such writs may be issued by (a) the RTC under Section 19; (b) CA under Section 9;
and (c) SC under Article VIII Section 5 of the Constitution. The 3 courts share concurrent
jurisdiction over these cases.

However the only difference is that writs issued by an RTC can only be enforced in the same
region where the RTC belongs. Unlike writs issued by the SC and CA, they can be enforced
anywhere in the Philippines.

[2] In actions affecting ambassadors and other public ministers and consuls.

The SC and RTC have original concurrent jurisdiction in actions affecting ambassadors, other
public ministers and consuls. Section 21 paragraph 2 states only of the concurrent original
jurisdiction of the SC and RTC. Section 19 on the jurisdiction of CA does not include the action
stated in section 21 paragraph 2 as part of its (CA’s) jurisdiction.

APPELLATE JURISDICTION OF THE RTC

Sec. 22. 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.

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Now take note that the RTC also has appellate jurisdiction under Section 22. These are cases
decided by the MTC. So they act as a sort of ‘court of appeals.’ The RTC exercises appellate
jurisdiction over all cases decided by the MTC in their respective territorial jurisdiction.

Q: How will the RTC decide on the appeal?

A: It shall be decided on the basis of the entire record of the proceedings had in the court of
origin (MTC) such as memoranda and/or briefs as may be submitted. This means that witnesses
will not be made to appear again in the appeal. It is only a matter of reviewing the testimony,
stenographic notes, evidence presented, memoranda and briefs by the RTC judge.

Q: What are memoranda and briefs?

A: It is where the appealing party will argue that the decision is wrong and try to convince the
judge that the decision is wrong, and the other party to counter act that the decision is correct.

Q: Assuming that the case is originated in the MTC and subsequently dismissed by the RTC on
appeal, is the decision by the RTC rendered pursuant to its appellate jurisdiction appealable to the
CA?
A: YES, but the mode of appeal is now different. The decision of the RTC in such cases shall be
appealable by petition to review to the CA. The CA may or may not give it due course.

Q: What is the difference between an appeal made from the RTC to CA and appeal from the
MTC to RTC, which is dismissed the same and subsequently appealed to the CA?
A: The former (RTC – CA) is in pursuance to the original jurisdiction of the RTC. The latter
(MTC-RTC-CA) is in pursuance to the appellate jurisdiction of the RTC. (They are governed by
different rules)

To illustrate:

Pursuant to original jurisdiction of the RTC: Pursuant to appellate jurisdiction of the RTC:

COURT OF APPEALS COURT OF APPEALS

Ordinary appeal Petition for Review

(Rule 41) (Rule 42)

RTC RTC

Ordinary Appeal
(Rule 40)

MTC

Unlike in a case under the original jurisdiction of the RTC, where an appeal to the CA is a
matter of course. Meaning, for as long as your appeal is on time and properly made, the CA will
entertain it.

It is different, however, in a case under the appellate jurisdiction of the RTC, even if your appeal
is on time and properly made, there is no assurance that the CA will entertain the appeal. The CA
may give it due course only when your petition for review shows prima facie evidence that the
lower court has committed as error of fact or law that will warrant a reversal or modification of the
decision or judgment sought to be reviewed.

Now, statistically for the past 20 years, the rate of petitions for review from the RTC which are
given due course is only 15%-17%. For every 100 petitions for review, 15 are given due course, 85
are thrown out. They did not pass the test under Section 22. It is really a difficult process.

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Summary of RTC jurisdiction:

1.) As to the EXCLUSIVE original jurisdiction – Section 19 (BP 129);
2.) As to its original CONCURRENT jurisdiction – Section 21 (BP 129);
3.) As to its APPELLATE jurisdiction – Section 22 (BP 129)

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