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1. Hannah Serana vs.

Sandiganbayan, 653 SCRA (2011) - SB

Ruling:
SB has jurisdiction over this case.

o PD 1606 - determines SB's jurisdiction; (not RA 3019 - does not contain an


enumeration of the cases over which the SB has jurisdiction; only defines
graft and corruption practices, and their penalties)

• UP Student Regent = public officer; not the salary grade that determines
the jurisdiction of the SB (only incidental to the public office) –
o Sec. 4(A)(1)(g) of PD No. 1606 explicitly vested the Sandiganbayan
with jurisdiction over Presidents, directors and trustees, or manager
of government-owned or controlled corporations, state universities,
or educational foundations. Petitioner falls under this category.

o Jurisdiction of the Sandiganbayan covers Board of Regents.


o performs functions similar to those of a board of trustee of a non-
stock corporation.

o The Sandiganbayan, also has jurisdiction over the other officers


enumerated in PD No. 1606.
• In Geduspan v. People, the SC held that while the first part of Sec.
4(A) covers only officials with Salary grade 27 and higher, its second
part specifically includes executive officials whose positions may not
be of SG 27 and higher but who are by express provisions of law
placed under the jurisdiction of the Sandiganbayan

o Offense committed in relation to public office


• Jurisdiction is determined by the averments in the
information; not affected by the pleas of the theories set up by
the defendant/respondent in an answer, MTD or MTQ -
otherwise, jurisdiction would become dependent almost
entirely upon the whims of D/R
2. Duncano vs. Sandiganbayan, 762 SCRA (2015) - SB

W/N the SB has jurisdiction over the P -NO

Doctrine:
o SB - "larger fish"; lower courts - "small fry"/"petty crimes"
o RA 7975, to speed up trial in the SB
• Intent: for SB to devote its time and expertise to big-time cases
involving the "big fishes" in the government; decongestion of SB's
dockets

o Positions classified as SG26 and below that fall under SB's jurisdiction
• Specifically enumerated by law

• SPECIFIC INCLUSION - Position held (not the SG) - determines the


jurisdiction of the SB
• except for those officials specifically included in Section 4 a. (1)
(a) to (g), regardless of their salary grades, over whom the
Sandiganbayan has jurisdiction, all other public officials below
SG 27 shall be under the jurisdiction of the proper trial courts
"where none of the principal accused are occupying positions
corresponding to SG 27 or higher."
§ Ut magis valeat quam pereat (that construction is to be
sought which gives effect to the whole of the statute – its
every word)

o P - NOT an executive official with SG27 or higher; DOES NOT hold any
position particularly enumerated among the exceptions (Sec.4.A.1 a-g)

o SB - NO jurisdiction over violations of Section 3(a) and (e), RA 3019, as


amended, unless committed by public officials and employees occupying
positions of regional director and higher with Salary Grade "27" or higher,
under the Compensation and Position Classification Act of 1989 (RA 6758)
in relation to their office.
3. De Lima vs. Guerrero, 843 SCRA (2017) - SB
RTC? Or SB?

Doctrine:
o Jurisdiction over the subject matter in a criminal case - given only by law
in the manner and form prescribed by law. It is determined by the statute
in force at the time of the commencement of the action.

o Congress has the plenary power to define, prescribe and apportion the
jurisdiction of various courts. It follows then that Congress may also, by
law, provide that a certain class of cases should be exclusively heard and
determined by one court.

o Special law - construed as an exception to the general law on jurisdiction


of courts.

o The pertinent special law governing drug-related cases is RA 9165, which


updated the rules provided in RA 6425, otherwise known as the
Dangerous Drugs Act of 1972. A plain reading of RA 9165, as of RA 6425,
will reveal that jurisdiction over drug-related cases is exclusively vested
with the Regional Trial Court and no other. The designation of the RTC as
the court with the exclusive jurisdiction over drug-related cases is
apparent in the following provisions where it was expressly mentioned
and recognized as the only court with the authority to hear drug-related
cases

4. City of Manila vs. Judge Cuerdo, February 4, 2014 - CTA

Whether or not the CTA has jurisdiction over a special civil action
for certiorari assailing an interlocutory order issued by the RTC in a local tax case -
CTA

Doctrine:
o Wrong remedy - special civil action for certiorari under R.65 (original or
independent action) cannot substitute lost appeal
o CTA - jurisdiction over a special civil action for certiorari assailing an
interlocutory order issued by the RTC in a local tax case.

• In order for any appellate court to effectively exercise its appellate


jurisdiction, it must have the authority to issue, among others, a writ
of certiorari in transferring exclusive jurisdiction over appealed tax
cases to the CTA; it can reasonably be assumed that the law intended
to transfer also such power as is deemed necessary, if not
indispensable, in aid of such appellate jurisdiction.

• There is no perceivable reason why the transfer should only be


considered as partial, not total.

o On the strength of the above constitutional provisions, it can be fairly


interpreted that the power of the CTA includes that of determining
whether or not there has been grave abuse of discretion amounting to
lack or excess of jurisdiction on the part of the RTC in issuing an
interlocutory order in cases falling within the exclusive appellate
jurisdiction of the tax court. It, thus, follows that the CTA, by
constitutional mandate, is vested with jurisdiction to issue writs
of certiorari in these cases.

5. CE Casecnan Water & Energy Co. vs. Prov. Of Nueva Ecija 759 CRA
180 - CTA (Expanded Jurisdiction)
Doctrine: - CTA’s jurisdiction
o CTA -exclusive jurisdiction over a special civil action for certiorari assailing an
interlocutory order issued by the RTC in a local tax case
• Rank - elevated to that of a collegiate court
• Expanded jurisdiction (RA 9282)
§ exclusive appellate jurisdiction to review by appeal the decisions, orders or
resolutions of the RTC in local tax cases originally decided or resolved by
the RTC in the exercise of its original or appellate jurisdiction
• the power of the CTA includes that of determining whether or not there
has been grave abuse of discretion amounting to lack or excess of
jurisdiction on the part of the RTC in issuing an interlocutory order in cases
falling within the exclusive appellate jurisdiction of the tax court (City of
Manila v Cuerdo)
6. Lomondot vs. Balindong, 762 SCRA 494 (SAC)

CA or Sharia appellate court's jurisdiction? - CA (Tomawis ruling)

Doctrine:
o Notably, Tomawis case was decided on March 5, 2010, while the CA
decision was rendered on April 27, 2010.

o The CA's reason for dismissing the petition, i.e., the decision came from
SDC which the CA has no appellate jurisdiction is erroneous for failure to
follow the Tomawis ruling.

o However, we need not remand the case, as we have, on several


occasions, passed upon and resolved petitions and cases emanating from
Shari’a courts.

7. Municipality of Tangkal vs. Balindong, 814 SCRA (2017) (SAC)

Whether or not the Shari'a District Court of Marawi City has jurisdiction in an action for
recovery of possession filed by Muslim individuals against a municipality whose mayor is
a Muslim - NO (RTC's jurisdiction); SDC no jurisdiction
Doctrine:
o Code of Muslim Personal Laws - SDC's jurisdiction
• it has a catchall provision granting Shari'a district courts
original jurisdiction over personal and real actions;
• XPN: those for forcible entry and unlawful detainer
• Concurrent with regular civil courts

• limit to the general jurisdiction of Shari'a district courts over matters


ordinarily cognizable by regular courts:
§ jurisdiction may only be invoked if both parties are Muslims
§ If one party is not a Muslim, the action must be filed before the
regular courts

o The ability to testify to the “oneness of God and the Prophethood of


Muhammad” and to profess Islam is restricted to natural persons.
8. Office of the Ombudsman vs. Mislang, 883 SCRA, Oct. 15, 2018
(Military Courts; Articles of War)

Case:
o OM (P) - dismissed charges against Valera
• Found Mislang (R), Durwin and Baharin guilty of grave misconduct
(substantial evidence), violation of the Articles of War; penalty -
dismissal from service

o R - appealed to the CA
• CA reversed and set aside P's decision
o respondent had been subjected to a General Court Martial at the
Philippine Army Headquarters, whereby respondent was adjudged not
guilty of the charges (res judicata) for the same acts in the complaint
• allegedly hatching a plot to kill the former Mayor of Lagayan, Abra,
Luna and her family; others wounded
o Does P have jurisdiction over the complaints against R? - YES;
o P or Court Martial? - Court-Martial – WHERE THE COMPLAINT IS FIRST FILED, to the
exclusion of all other courts
o Petition - DENIED

Doctrine:
o Ombudsman and the General Court Martial of the AFP
• concurring or coordinate jurisdiction over administrative
disciplinary cases involving erring military personnel,
particularly over violations of the Articles of War that are
service-connected
o Court-martial
• is a court
• prosecution of an accused before it is a criminal, NOT an
administrative case
• proceedings contemplate both the penal and administrative
disciplinary nature of military justice
• Service-oriented
o P and court-martial
• concurrent authority to dismiss respondent from the service
(in view of its administrative disciplinary aspect)
9. Unduran vs. Aberasturi, 823 SCRA (2017) (Primary Jurisdiction)

W/N the RTC has jurisdiction over the disputes and controversies involving ancestral
domain of the ICC and IP regardless of the parties involved? - YES (not the NCIP)

Doctrine:
o RTC - court of general jurisdiction
• Power and authority to hear and decide cases whose subject
matter DOES NOT fall within the exclusive original jurisdiction
of any court, tribunal or body exercising judicial/quasi-judicial
function

o (while) Court of Limited Jurisdiction - court acting under special powers


• ONLY the jurisdiction EXPRESSLY delegated

o Administrative agency (acting in quasi-judicial capacity)


• tribunal of limited jurisdiction; could wield only such powers
that are specifically granted to it by the enabling statutes

o Limited or special jurisdiction


• confined to particular causes or which can be exercised only
under limitations and circumstances prescribed by the statute

o NCIP's jurisdiction - limited under customary laws (S. 66 of IPRA) - only


when they arise between and among parties belonging to the same ICC/IP
group; otherwise - regular court; XPNs - Sections 52, 54 and 62 of the
IPRA
• Sec. 66 - did not use "primary" and/or "original and exclusive" to
describe the jurisdiction of the NCIP over "all claims and disputes
involving rights of ICCs/Ips"

§ Concurrent or coordinate jurisdiction - exercised by different courts


• at the same time
• over the same subject matter and
• within the same territory, and
• wherein litigants may in the first instance resort to either
court indifferently,
• that of several different tribunals, each authorized to deal
with the same subject matter, and
• when a proceeding in respect of a certain subject matter can
be brought in any one of several different courts, they are said
to have concurrent jurisdiction

§ Courts of equal dignity as to matters concurrently cognizable,


neither having supervisory power over process from the other
• Rule: court which first takes cognizance of an action
over which it has jurisdiction and power to afford
complete relief has the exclusive right to dispose of
the controversy without interference from other
courts of concurrent jurisdiction
§ (Principle of Priority or Rule of Exclusive Concurrent
Jurisdiction)
• to reduce the possibility of the conflicting exercise of
concurrent jurisdiction, especially to reduce the possibility
that a case involving the same subject matter and the same
parties is simultaneously acted on in more than one court

§ Primary jurisdiction - power and authority vested by the Constitution or by


statute upon an administrative body to act upon a matter by virtue of its
specific competence

§ Enabling statute - yardsticks by which the Court would measure


the quantum of quasi-judicial powers that an administrative
agency may exercise, as defined in the enabling act of such
agency
10.LBP vs. Dalauta, 835 SCRA (2017) (Primary Jurisdiction)

Whether the trial court had properly taken jurisdiction over the case despite the finality
of the PARAD resolution? - YES
petition for review under Rule 42

Doctrine:
o Jurisdiction of the DARAB (in agrarian reform cases)
§ The doctrine of primary jurisdiction tells us that courts cannot,
and will not, resolve a controversy involving a question which
is within the jurisdiction of an administrative tribunal,
especially 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.
§ EO 229:
• Quasi-judicial powers to determine and adjudicate
agrarian reform matters
• Jurisdiction over all matters involving the
implementation of agrarian reform (XPN: those
falling under the E/O jurisdiction of the DA and the
DENR)

11.Dev. Bank of the Phil. Vs. Carpio, 816 SCRA (2017) (Residual Jurisdiction)
Whether or not the court erred in its blind adherence to and strict application of section
20, Rule 57 of the 1997 Rules of Civil Procedure (Claim for Damages on Account of Illegal
Attachment) - NO
Doctrine:
o The trial court did not reach the residual jurisdiction stage.
• The "residual jurisdiction" of the trial court is
o available at a stage in which the court is normally deemed to have lost
jurisdiction over the case or the subject matter involved in the appeal.
o This stage is reached:
• upon the perfection of the appeals by the parties or
• upon the approval of the records on appeal,
• but prior to the transmittal of the original records or the records
on appeal.
o In either instance, the trial court still retains its so-called residual
jurisdiction to:
• issue protective orders,
• approve compromises,
• permit appeals of indigent litigants,
• order execution pending appeal, and
• allow the withdrawal of the appeal.

o Before the trial court can have residual jurisdiction over a case:
• A trial on merits must have been conducted
• The court rendered judgment, and
• The aggrieved party appealed therefrom

12.Regulus Development, Inc. vs. De la Cruz, 781 SCREA (2016) (Requisites: trial,
judgment, appeal)
RTC had jurisdiction to levy on R's real property? - YES

Doctrine:
o Equity vs Appellate Jurisdiction of the RTC
APPELLATE JURISDICTION EQUITY JURISDICTION
Conferred by law Aims to provide complete in cases where a court of
law is unable to adapt its judgments to the special
circumstances of a case because of a resulting legal
inflexibility when the law is applied to a given
situation
Acquired when an appeal is Purpose:
perfected • to prevent unjust enrichment
(over subject matter and • to ensure restitution
parties)

o The RTC, as the court of origin, has jurisdiction to order the levy of the
respondent's real property.

Rationale: Our courts are courts of law and EQUITY; principle of honesty and
fairness
13.Resident Marine Mammals vs. Reyes, 756 SCRA (2015) Epistolary Jurisdiction

Resident Marine Mammals and the human petitioners also assert that through
this case, this court will have the opportunity to lower the threshold for locus
standi as an exercise of "epistolary jurisdiction." (G.R. No. 180771; April 21,
2015)
Doctrine:
o Judiciary in late 20th century has invented the devise of Public Interest Litigation
(herein after refereed to as PIL) which has become a main weapon in the armory
to deliver speedy justice at affordable costs. Further judiciary has adopted new
kinds of procedural techniques while dealing with PIL. Many technical rules of
procedure have been relaxed; the burden of the individual in fighting the
litigation is reduced by various beneficial principles. Acting on letters written by
or on behalf of the oppressed people is a strategy adopted by the Supreme
Court for facilitating access to justice. This is known as ‘epistolary jurisdiction.’
The letters have been converted into writ petitions on the logic that Article 32 of
the Constitution does not say as to “who” shall have the right to move the
Supreme Court, nor does it say by “what” proceedings. The expression
“appropriate proceedings” is too wide, and so moving the court through a letter
can be appropriate proceedings because it would not be right to expect a person
acting pro bono public to incur expenses from his pocket for having a regular
writ petition prepared by a lawyer. It has to be appropriate not in terms of any
particular form, but appropriate with reference to the purpose of the
proceeding.

• Epistolary Jurisdiction - IT IS A THRESHOLD OF PARTIES; INCREASING THE


THRESHOLD OF THE HIERARCHY OF COURTS
o PIL - deals with the liberalization or relaxation of the rule on standing
or locus standing whereby groups and proactive individuals are
allowed to approach the court on behalf of disadvantaged individuals
and groups to seek remedy for their social infirmities.
o The Court through a letter sent to it may act on a certain case.
o Used to demand courts to take on social issues which would in some
instances, would otherwise had been traditionally the scope of
executive or legislative departments.
• Invoking this is couched under the universal right to access to
justice, which is a fundamental and universal human right
14.City of Manila vs. Judge Cuerdo (2014) - Split Jurisdiction

Whether or not the CTA has jurisdiction over a special civil action for certiorari assailing
an interlocutory order issued by the RTC in a local tax case - CTA
Doctrine:

o On the strength of the above constitutional provisions, it can be fairly


interpreted that the power of the CTA includes that of determining
whether or not there has been grave abuse of discretion amounting to
lack or excess of jurisdiction on the part of the RTC in issuing an
interlocutory order in cases falling within the exclusive appellate
jurisdiction of the tax court. It, thus, follows that the CTA, by
constitutional mandate, is vested with jurisdiction to issue writs
of certiorari in these cases.

The exercise by two judicial bodies, of jurisdiction over basically the same
subject matter – precisely the split jurisdiction situation which is anathema to
the orderly administration of justice.

The power of judicial review trickles down to the lower courts, including the
CTA. (Constitutional)

15.Edcel Lagman vs. Pimentel III, 854 SCRA (2018) Expanded/Extended Jurisdiction

Whether or not the petitioners may invoke the expanded (certiorari) jurisdiction of the
Supreme Court under Section 1, Article VIII of the Constitution in seeking review of the
extension of Proclamation No. 216 - NO

Doctrine:
Expanded jurisdiction - Jurisdiction of a court which is expanded and its rank
elevated to that of a collegiate court with special jurisdiction.
16.Duero vs CA – 373 SCRA 11 - Jurisdiction estoppel
• Which court had jurisdiction over the case? - MTC
• Whether PR Eradel is estopped from questioning the jurisdiction of RTC after he
has successfully sought affirmative relief therefrom - NO (CA's ruling is affirmed.)

Doctrine:
o For estoppel to apply, the action giving rise thereto must be unequivocal
and intentional because, if misapplied, estoppel may become a tool of
injustice.

o Note that private respondent raised the issue of lack of jurisdiction, not
when the case was already on appeal, but when the case, was still before
the RTC that ruled him in default, denied his motion for new trial as well
as for relief from judgment, and denied likewise his two motions for
reconsideration

o The fundamental rule is that, the lack of jurisdiction of the court over an
action cannot be waived by the parties, or even cured by their silence,
acquiescence or even by their express consent. Further, a party may
assail the jurisdiction of the court over the action at any stage of the
proceedings and even on appeal. The appellate court did not err in
saying that the RTC should have declared itself barren of jurisdiction
over the action.

o Citing Javier v CA, the Court reiterated: Under the rules, it is the duty of
the court to dismiss an action 'whenever it appears that the court has no
jurisdiction over the subject matter.' (Sec. 2, Rule 9, Rules of Court)

17.Gonzaga vs CA - 394 SCRA 472 - Jurisdiction Estoppel


Doctrine:
o The SC held that the doctrine in Tijam v. Sibonghanoy, as reiterated in
numerous cases, is still controlling. In explaining the concept of
jurisdiction by estoppel, the Court quoted its decision in said case, to wit:
o It has been held that a party cannot invoke the jurisdiction of a
court to secure affirmative relief against his opponent and, after
obtaining or failing to obtain such relief, repudiate, or question that
same jurisdiction x x x x [T]he question whether the court had
jurisdiction either of the subject matter of the action or of the
parties was not important in such cases because the party is barred
from such conduct not because the judgment or order of the court is
valid and conclusive as an adjudication, but for the reason that such
a practice can not be tolerated–– obviously for reasons of public
policy.

o Furthermore, the Court said that it was petitioners themselves who


invoked the jurisdiction of the court a quo by instituting an action for
reformation of contract against private respondents. It must be noted
that in the proceedings before the trial court, petitioners vigorously
asserted their cause from start to finish. Not even once did petitioners
ever raise the issue of the court’s jurisdiction during the entire proceedings
which lasted for two years.
• It was only after the trial court rendered its decision and issued
a writ of execution against them in 1998 did petitioners first
raise the issue of jurisdiction ─ and it was only because said
decision was unfavorable to them. Petitioners thus effectively
waived their right to question the court’s jurisdiction over the
case they themselves filed.

18.Manila Bankers vs. Ng Kok Wei, 418 SCRA - Jurisdiction Estoppel

Whether RTC has jurisdiction over the case - NO


Is P estopped from questioning RTC's jurisdictiong? YES

Doctrine: (Exception to the general rule that jurisdiction is not conferred by


consent, silence or acquiescence - estoppel by laches)
• While it may be true that the trial court is without jurisdiction over the case,
petitioner’s active participation in the proceedings estopped it from
assailing such lack of it. We have held that it is an undesirable practice of a
party participating in the proceedings and submitting its case for decision
and then accepting the judgment, only if favorable, and attacking it for lack
of jurisdiction, when adverse.
19.Boston Equity Resources, Inc. vs. CA, 699 SCRA - Jurisdiction Estoppel

Whether or not the RTC acquired jurisdiction over the person of Manuel; - NO
Whether or not respondent may still assail the question of jurisdiction of Manuel
on her motion to dismiss? - NO

Doctrine:
o NO. Here, what respondent was questioning in her motion to dismiss
before the trial court was the court’s jurisdiction over the person of the
defendant Manuel.
• Thus, the principle of estoppel by laches finds no application
in his case. Instead the principles relating to jurisdiction are
pertinent therein.
• Since the defense of lack of jurisdiction over the person of a
party to a case is not one of those defenses which are not
deemed waived under Section 1 of Rule 9, such defense must
be invoked when an answer or a motion to dismiss is filed in
order to prevent a waiver of the defense. If the objection is not
raised either in a motion to dismiss or in the answer, the
objection to the jurisdiction over the person of the plaintiff or
the defendant is deemed waived by virtue of the first sentence
of the above quoted Section 1, Rule 9 of the Rules of Court.
As a question of jurisdiction raised here is that over the person of Manuel,
• deemed waived if not raised in the answer or a motion to dismiss.
• In any case, respondent cannot claim the defense since “lack of
jurisdiction over the person, being subject to waiver, is a personal
defense which can only be asserted by the party who can thereby
waive it by silence.”
20.Agan vs. Piatco, 420 SCRA - Hierarchy of Courts

Doctrine:
o The rule on the hierarchy of courts will also not prevent the SC from
assuming jurisdiction as the rule may be relaxed when the redress
sought cannot be obtained in the appropriate courts and where
exceptional and compelling reasons justify the availment of the remedy.

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