JURISDICTION OF RTC

De Jesus v. Garcia
GR L-26816
Specific
incapable
estimation

performance

of
pecuniary

The averments of the complaint,

taken as a whole, are what
determine the nature of the action,
and
therefore,
the
court's
jurisdiction.
A
careful
and
considerate
examination of the complaint as a
whole brings to the fore the fact
that plaintiff Maxima de Jesus asks
that these defendants comply
faithfully with their respective
commitments. Implicit, too, in the
complaint is the demand that her
said co-owners recognize her as
administratrix. It is in the context
just recited that plaintiff's action
below comes within the concept of
specific
performance
of
contract. The payments would be
but an incident or consequence
of defendant's liability for
specific performance.
Raymundo v. CA
GR 97805 | September 2, 1992
Test in determining whether an
action is incapable of pecuniary
estimation
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 [now municipal trial courts]
or in the courts of first instance
[now regional trial courts] would
depend on the amount of the
claim. However, where the basic
issue is something other than the
right to recover a sum of money, or
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
are
cognizable exclusively by courts of
first instance [now regional trial
courts].
Gutierez v. CA
GR No. 82475
Res Judicata; judicial stability
Res judicata means that a final
judgment or decree on the merits
by
a
court
of
competent
jurisdiction is conclusive of the
rights of the parties or their
privies in all later suits on points
and matters determined in the
former suit
For res judicata to operate as a bar
to the re-opening of a matter
already judicially determined by
competent authority, the following
requisites must concur: (1) the
former judgment or order must be
final; (2) it must be a judgment or
order on the merits; (3) it must

have been rendered by a court

having
jurisdiction
over
the
subject-matter and the parties; and
(4) there must be, between the
first and second actions, identity of
parties, subject matter and cause
of action
A party may not evade the
application of the rule of res
judicata
by
simply
including
additional
parties
in
the
subsequent case or by not
including as parties in the later
case persons who were parties in
the previous suit.
The test of identity of causes of
action lies not in the form of an
action but on whether the same
evidence would support and
establish the former and the
present causes of action. The
difference of actions in the
aforesaid cases is of no moment.
It has been held that a party
cannot by varying the form of
action or adopting a different
method of presenting his case,
escape the operation of the
principle that one and the same
cause of action shall not be
twice litigated between the
same parties and their privies.

Judicial stability
These two courts are of the same
class and category. Both discharge
functions which are co-equal in
character. Pursuant to the policy
of judicial stability, the judgment of
a court of competent jurisdiction
may not be interfered with by any
court of concurrent jurisdiction.

For the same reason, the power to

open, modify or vacate a judgment
is not only possessed by, but is
restricted to the court in which the
judgment was rendered. It is
regarded
as
an
elementary
principle of high importance in the
administration of justice that the
judgment of a court of competent
jurisdiction may not be opened,
modified, or vacated by any court
of concurrent jurisdiction.
Bayhon v. Santos
G.R. No. 88643, July 23, 1991
Judicial Stability exception
The general rule that no court has
the
power
to
interfere
by
injunction with the judgments or
decrees of another court with
concurrent
or
coordinate
jurisdiction
possessing
equal
power to grant injunctive relief,
applies only when no third - party
claimant is involved. When a third
- party, or a stranger to the action,
asserts a claim over the property
levied upon, the claimant may
vindicate
his
claim
by
an
independent action in the proper
civil court which may stop the
executive of the judgment on
property not belonging to the
judgment debtor.
De Leon v. CA
GR No. 96107 | June 19, 1995
Ejectment
incapable
estimation

action
of

v. action
pecuniary

A detainer suit exclusively involves

the issue of physical possession.

The case below, however, did not
concern merely the issue of
possession but as well, the nature
of
the
lease
contracted
by
petitioner's predecessor-in-interest
and
private
respondent.
It
likewise involved the propriety of
terminating
the
relationship
contracted by said parties, as well
as the demand upon defendant to
deliver the premises and pay
unpaid rentals, damages and
incidental
fees.
Where the issues of the case
extend beyond those commonly
involved in unlawful detainer suits,
such as for instance, the respective
rights of parties under various
contractual arrangements and the
validity thereof, the case is
converted from a mere detainer
suit to one "incapable of pecuniary
estimation," thereby placing it
under
the
exclusive
original
jurisdiction of the regional trial
courts.

of Rizal had already acquired

jurisdiction over the question of
foreclosure of mortgage over the
La Vista property and rendered
judgment in relation thereto, then
it retained jurisdiction to the
exclusion of all other coordinate
courts over its judgment, including
all incidents relative to the control
and conduct of its ministerial
officers, namely the sheriff thereof.
The foreclosure sale having been
ordered by Branch V of the CFI of
Rizal, TCC should not have filed
injunction
proceedings
with
Branch XXI of the same CFI, but
instead should have first sought
relief by proper motion and
application from the former court
which had exclusive jurisdiction
over the foreclosure proceeding.
This doctrine of non-interference is
premised on the principle that a
judgment of a court of competent
jurisdiction may not be opened,
modified or vacated by any court
of concurrent jurisdiction.

PNB v. Pineda
GR L-46658 | May 13, 1991

Oblea v. CA
GR No. 117389 | May 11, 1995

Doctrine of non-interference

Petition for quieting of title

does not divest jurisdiction of
the court on ejectment cases.

FACT:
Writ
of
preliminary
injunction is issued against a
foreclosure order rendered by
another branch of court in the
CFI/RTC.
RULING: Another reason for
striking
down
the
writ
of
preliminary injunction complained
of is that it interfered with the
order of a co-equal and coordinate
court. Since Branch V of the CFI

Facts: Oblea was a mere lessee of

the subject property when it was
bought by certain a Esteban. As a
consequence, Esteban filed an
ejectment case against Oblea.
Oblea then filed a quieting of title
against Esteban.

RULING: The pendency of an

action for quieting of title before
the Regional Trial Court does not
divest the city or municipal trial
court of its jurisdiction to proceed
with the ejectment case over the
same property. The subsequent
acquisition
of
ownership
by
petitioners is not a supervening
event that will bar the execution of
the judgment in said unlawful
detainer case, the fact remaining
that when judgment was rendered
by the MTC in the ejectment case,
petitioner Oblea was a mere
possessor of the subject lot.
Similarly, the fact that petitioners
instituted a separate action for
quieting of title is not a valid
reason for defeating the execution
of the summary remedy of
ejectment. On the contrary, it
bolsters the conclusion that the
eviction-case did not deal with the
issue of ownership which was
precisely the subject matter of the
action for quieting of title before
the Regional Trial Court of
Cabanatuan City.7 With the finality
of the decision in the ejectment
case, execution in favor of the
prevailing party has become a
matter of right; its implementation
mandatory. It cannot be avoided.
Mendoza v. The
GR 122646 | March 14, 1997
Appointment as administrator
is not a settlement of the estate
that is properly vested in the
probate court; appointment of
administratix
is
an
action
incapable
of
pecuniary
estimation.

In the present suit, no settlement

of estate is involved, but merely an
allegation seeking appointment as
estate administratrix which does
not necessarily involve settlement
of estate that would have invited
the
exercise of
the
limited
jurisdiction of a probate court. The
above allegation is not even a
jurisdictional fact which must be
stated
in
an
action
for
reconveyance.
The
Court
therefore, should have at least,
proceeded with the reconveyance
suit rather than dismiss the entire
case.

JURISDICTION OF MTC
RCBC v. Isnani
GR 117383 | March 06, 1995
Transfer of a case pending
before the RTC after the
effectivity of RA 7691 (Judicial
Reorganization Act) to MTC for
proper jurisdiction is allowed
on certain conditions. In this
case, the complaint was already
filed (not pending) with the
RTC when the law became
effective. Thus, the latter does
not apply.
Semira v. CA
GR No. 76031 | March 2, 1994
Deciding ownership in forcible
entry cases does not bar nor
prejudice an action between
the same parties involving title
to the land.

The issue of possession cannot be

decided independently of the
question of ownership.
The case before us is merely an
action for forcible entry and that
the issue of ownership was
decided for the sole purpose of
resolving priority of possession.
Hence, any pronouncement made
affecting
ownership
of
the
disputed portion is to be regarded
merely as provisional, hence, does
not bar nor prejudice an action
between
the
same
parties
involving title to the land.
Bejer v. CA
GR No. 79404 | January 27, 1989
For purposes of venue it has been
held that the residence of a person
is his personal, actual or physical
habitation or his actual residence
or place of abode which may not
necessarily be his legal residence
or domicile provided he resides
therein
with
continuity
and
consistency. It signifies physical
presence in a place and actual stay
thereat. x x x No particular length
of time of residence is required
though; however, the residence
must be more than temporary

JUDICIAL STABILITY
Ngo Bun Tiong v. Sayo
GR L-45825 | June 30, 1988
The lone issue raised by petitioner
is whether or not a Court of First
Instance or a branch thereof, has
jurisdiction to annul or set aside,
for
alleged
irregularities
an

execution sale, held by virtue of a

decision rendered by another
Court of First Instance or a branch
thereof, and subsequently to order
the return of the properties sold at
public auction to the judgment
debtor.
It has long been settled that no
court has the power to interfere by
injunction, with the judgments or
decrees of a court of concurrent or
coordinate
jurisdiction
having
equal power to grant the relief
sought by injunction. Even more
emphatically, this Court ruled that
"Pursuant to the policy of judicial
stability, the judgment of a court of
competent jurisdiction may not be
interfered with by any court of
concurrent jurisdiction. For the
simple reason that the power to
open, modify or vacate a
judgment is not only possessed
by, but is restricted to the court
in which the judgment was
rendered."

Doctrine
of
Jurisdiction

Primary

Provident
Tree
Farms
Batayog
GR 92285 | March 28, 1994

v.

The question that deals with

importation whether valid or
invalid under a specific statute
is in the prerogative of an
administrative body
Fact: Involves a Petition for
injunction with damages
Petitioner anchors his complaint
on
a
statutory privilege
or

incentive granted under Sec. 36,

par. (1), of the Revised Forestry
Code. The only subject of this
incentive
is
a
ban
against
importation
of
wood,
wood
products
or
wood-derivated
products which is to be enforced
by the Bureau of Customs since it
has, under the Tariff and Customs
Code,
the
exclusive
original
jurisdiction over seizure and
forfeiture cases[13] and, in fact, it is
the duty of the Collector of
Customs to exercise jurisdiction
over prohibited importations.[14]
The enforcement of the import ban
under Sec. 36, par. (1), of the
Revised Forestry Code is within
the exclusive realm of the Bureau
of Customs, and direct recourse of
petitioner to the Regional Trial
Court to compel the Commissioner
of Customs to enforce the ban is
devoid of any legal basis. To allow
the regular court to direct the
Commissioner to impound the
imported matches, as petitioner
would, is clearly an interference
with the exclusive jurisdiction of
the Bureau of Customs over
seizure and forfeiture cases.
Under the sense-making and
expeditious doctrine of primary
jurisdiction x x x the courts cannot
or will not determine a controversy
involving a question which is
within the jurisdiction of an
administrative tribunal, where the
question demands the exercise of
sound administrative discretion
requiring the special knowledge,

experience, and services of the

administrative
tribunal
to
determine technical and intricate
matters of fact, and a uniformity of
ruling is essential to comply with
the purposes of the regulatory
statute administered.
But this does not preclude
recourse to the courts by way of
the
extraordinary
relief
of
certiorari under Rule 65 of the
Rules of Court if the Bureau of
Customs should gravely abuse the
exercise
of
its
jurisdiction.
Otherwise stated, the court cannot
compel an agency to do a
particular act or to enjoin such act
which is within its prerogative,
except when in the exercise of its
authority it gravely abuses or
exceeds its jurisdiction.
Industrial Enterprise Inc. v. CA
Ordinary
civil
action
of
rescission is cognizable by an
administrative body if it is
within the statutory provisions
that it can pass upon any
question of rescission
Fact: IEI filed an action for
rescission of the MOA with
damages against MMIC and the
Minister of Energy.
The decisive issue in this case is
whether or not the civil court has
jurisdiction to hear and decide the
suit
for
rescission
of
the
Memorandum
of
Agreement
concerning
a
coal
operating
contract over coal blocks.
A

corollary question is whether or

not it is the Bureau of Energy
Development (BED) which has
jurisdiction over said action and
not the civil court.
While the action filed by IEI sought
the rescission of what appears to
be an ordinary civil contract
cognizable by a civil court, the fact
is that the Memorandum of
Agreement sought to be rescinded
is derived from a coal-operating
contract and is inextricably tied up
with the right to develop coalbearing
lands
and
the
determination of whether or not
the reversion of the coal operating
contract over the subject coal
blocks to IEI would be in line with
the integrated national program
for coal-development and with the
objective of rationalizing the
country's
over-all
coal-supplydemand balance. IEI's cause of
action
was
not
merely
the
rescission of a contract but the
reversion or return to it of the
operation of the coal blocks.
It may occur that the Court has
jurisdiction to take cognizance of a
particular case, which means that
the matter involved is also judicial
in character. However, if the case
is such that its determination
requires the expertise, specialized
skills and knowledge of the proper
administrative
bodies
because
technical matters or intricate
questions of fact are involved, then
relief must first be obtained in an
administrative proceeding before a

remedy will be supplied by the

courts even though the matter is
within the proper jurisdiction of
court. This is the doctrine of
primary jurisdiction. It applies
"where a claim is originally
cognizable in the courts, and
comes
into
play
whenever
enforcement of the claim requires
the resolution of issues which,
under a regulatory scheme, have
been placed within the special
competence of an administrative
body; in such case the judicial
process is suspended pending
referral of such issues to the
administrative body for its view.

ELEMENTS
OF
CAUSE OF ACTION
Heirs of Coscolluela v. Rico
General Insurance Corporation
The allegations set forth in the
complaint sufficiently establish
a cause of action. The following
are the requisites for the existence
of a cause of action: (1) a right in
favor of the plaintiff by whatever
means and under whatever law it
arises or is created; (2) an
obligation on the part of the
named defendant to respect, or not
to violate such right; and (3) an act
or omission on the part of the said
defendant constituting a violation
of the plaintiff's right or a breach
of the obligation of the defendant
to the plaintiff.

The facts as alleged clearly define

the existence of a right of the
petitioner to a just claim
against the insurer for the
payment of the indemnity for a loss
due to an event against which the
petitioner's vehicle was insured.
The
insurance
contract
mentioned therein manifests a
right to pursue a claim and a
duty on the part of the insurer
or
private
respondent
to
compensate the insured in case
of a risk insured against. The
refusal of the insurer to satisfy
the claim and the consequent
loss
to
the
petitioner
in
incurring the cost of acquiring
legal assistance on the matter
constitutes a violation or an
injury brought to the petitioner.
DBP v. Sima Wei
The payee of a negotiable
instrument acquires no interest

with respect thereto until its

delivery to him. Delivery of an
instrument means transfer of
possession, actual or constructive,
from one person to another.
Without the initial delivery of
the instrument from the drawer
to the payee, there can be no
liability on the instrument.
Moreover, such delivery must be
intended to give effect to the
instrument.
The allegations of the petitioner in
the original complaint show that
the two (2) China Bank checks,
numbered 384934 and 384935,
were not delivered to the payee,
the petitioner herein. Without the
delivery of said checks to
petitioner-payee, the former
did not acquire any right or
interest therein and cannot
therefore assert any cause of
action, founded on said checks,
whether against the drawer Sima
Wei or against the Producers Bank
or any of the other respondents.