HIERARCHY OF

PHILIPPINE COURTS

LEGAL COUNSELING Pros. Jenifer Bagay Mirafuentes, Jonalyn L.

13 May 2022 Professor JD IV
 Doctrine of Hierarchy of Courts
2 Pursuant to this doctrine, a case must be filed first before
the lowest court possible having the appropriate
jurisdiction, except if one can advance a special reason
which would allow a party a direct resort to a higher court.
Two-fold Rationale:
1. It would be an imposition upon the limited time of the
Supreme Court (SC);
2. It would inevitably result in a delay, intended or
otherwise, in the adjudication of cases, which in some
instances, had to be remanded or referred to the lower
court as the proper forum under the rules of procedure,
or as better equipped to resolve the issues because the
SC is not a trier of facts.
- It is only for special and compelling reasons that the SC
shall exercise its primary jurisdiction over cases.
The doctrine requires respect for the
hierarchy of courts which was created
by the court to ensure that every level
of the judiciary performs its
designated roles in an effective and
efficient manner.
Thus, where courts have
concurrence of jurisdiction over a
subject matter, such concurrence of
jurisdiction does not grant the party
seeking relief the absolute freedom to
file a petition in any court of his
choice.
3
 What is hierarchy of Courts?
- Pursuant to this doctrine, a case must be filed first before the lowest court possible having the appropriate
jurisdiction, except if one can advance a special reason which would allow a party a direct resort to a higher court

4 In the Philippine setting, in the hierarchy of courts, the SC is the highest tribunal, while the first level courts are
composed of the:
a. METROPOLITAN TRIAL COURTS (MeTC) – metropolitan area
b. MUNICIPAL TRIAL COURTS IN CITIES (MTCC) – cities outside Metro Manila
c. MUNICIPAL TRIAL COURTS (MTCs) – municipalities outside Metro Manila
d. MUNICIPAL CIRCUIT TRIAL COURTS (MCTC) – each circuit composed of cities and/or municipalities as
grouped together
OR AS THEY ARE COLLECTIVELY CALLED – THE MTC
e. Another court which is classified as same level as the MTC are the Shari’a Courts
- A shari’s court Only deals with Muslim customary and personal laws & exclude criminal law

Among the courts in the Philippines, the first level courts do not have the appellate jurisdiction because generally, they are
the lowest court possible which may have the appropriate jurisdiction.

Moreover, the Shari’a District courts cannot be the subject of appellate jurisdiction of CA, CTA or Sandiganbayan because
its decisions whether on appeal from the Shari’a Circuit Court or not shall be final BUT WITHOUT PREJUDICE AND
SHALL NOT affect the original and appellate jurisdiction of the Supreme Court as provided in the Constitution.

Pursuant to exclusive original jurisdiction of courts, a particular case may not necessarily be tried in MTC or any lowest
court possible and be automatically tried before the RTC, CA, CTA or Sandiganbayan, or even by the SC, as the case may
be.
Applicable Laws:
“
1. 1987 Philippine Constitution
2. Batas Pambansa Bilang 129 – The Judiciary Reorganization Act
of 1980
3. Republic Act No. 7691 – An Act Expanding the Jurisdiction of
MTCs Amending for the Purpose BP Blg. 129
4. Republic Act No. 11576 – An Act Further Expanding the
Jurisdiction of MTCs Amending for the Purpose BP Blg. 129, As
Amended
5. Article 155 of Presidential Decree No. 1083 (Code of Muslim
Persons Laws of the Philippines
6. Republic Act No. 6657 – Comprehensive Agrarian Reform Law
of 1988
7. Republic Act No. 9282- An Act Expanding the Jurisdiction of
Court if Tax Appeals (CTA)
8. Executive Order Nos. 1, 2, 14 & 14-A of 1986

5
 “
Let’s now discuss each level
of the hierarchy of courts

6
 1
1st Level Courts: Collectively, the MTC

1. METROPOLITAN TRIAL COURTS (MeTC) – metropolitan area

2. MUNICIPAL TRIAL COURTS IN CITIES (MTCC) – cities outside Metro Manila
3. MUNICIPAL TRIAL COURTS (MTCs) – municipalities outside Metro Manila
4. MUNICIPAL CIRCUIT TRIAL COURTS (MCTC) – each circuit composed of cities
and/or municipalities as grouped together
 MTCs: Jurisdiction
Exclusive Original – Civil Cases, Others
8 1. Civil actions, probate matters, testate and intestate
whose totality of value of the personal property, estate
or amount of the demand does not exceed P2M,
exclusive of interest, damages or whatever kind,
attorney’s fees, litigation expenses, and costs
2. All civil actions which involve title to, or possession
of, real property, or any interest therein where the
assessed value of the property or any interest therein
does not exceed P400K exclusive of interest, damages,
etc
3. Admiralty and maritime actions where the demand
or claim does not exceed P2M
Exclusive Original – Criminal Cases
1. All violations of city or municipal ordinances
2. All offenses punishable with imprisonment not exceeding six (6)
years irrespective of the amount of fine
3. In all cases of damage to property through criminal negligence,
regardless of other penalties and the civil liabilities arising
therefrom
4. All offenses (except violations of RA 3019, RA 1379 and Articles
210-212 of the RPC) committed by public officers & employees in
relation to their office & by private individuals charges as co-
principals, accomplices or accessories, punishable w/ imprisonment
of not more than 6 years w/ a salary grade of less than 27
 MTCs: Jurisdiction

Delegated Jurisdiction in cadastral or land registration cases covering lots where there is no
9
Cadastral & Land controversy or opposition, or contested lots the where the value of which
Registration Cases does not exceed P100K

Special Jurisdiction in In the absence of all the Regional Trial Judges in a province or city, any
Certain Cases Metropolitan Trial Judge, Municipal Trial Judge, Municipal Circuit Trial
Judge may hear and decide petitions for a writ of habeas corpus or
applications for bail in criminal cases in the province or city where the
absent Regional Trial Judges sit.

Summary Procedures in In Metropolitan Trial Courts and Municipal Trial Courts with at least two
Special Cases branches, the Supreme Court may designate one or more branches thereof
to try exclusively the following cases:
1. Forcible entry
2. Unlawful detainer
3. Violations of traffic laws, rules and regulations
4. Violations of the rental law
5. Other cases requiring summary disposition as the SC may determine
 SHARI’A CIRCUIT COURTS: Jurisdiction
Exclusive Original Jurisdiction Over:
10
(1) All cases involving offenses defined and punished under this Code.
(2) All civil actions and proceedings between parties who are Muslims or have been
married in accordance with Article 13 involving disputes relating to:
(a) Marriage;
(b) Divorce recognized under this Code;
(c) Betrothal or breach of contract to marry;
(d) Customary dower (mahr);
(e) Disposition and distribution of property upon divorce;
(f) Maintenance and support, and consolatory gifts, (mut'a); and
(g) Restitution of marital rights.
(3) All cases involving disputes relative to communal properties.

Art. 155, PD 1083 - Code of Muslim Personal Laws of the Philippines

- Only deals with Muslim customary and personal laws & exclude
criminal law
 “
And now we’re off to the
Second Level Courts…

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 REGIONAL TRIAL COURTS: Jurisdiction
Exclusive Original Jurisdiction Over Civil Cases:
12
1. Civil actions in which the subject of litigation is incapable of pecuniary estimation;

2. Civil actions which involve the title to, or possession of, real property, or any interest therein,
where the assessed value exceeds P400k, except for forcible entry into and unlawful detainer
of lands or buildings, original of which is conferred upon the MeTCs, and MTCCs, MTCs,
and MCTCs;

3. Actions in admiralty and maritime jurisdiction where the demand or claims exceeds P2M;

4. Matters of probate, both estate and intestate, where the gross value of the estate exceeds P2M;

5. Actions involving the contract of marriage and marital relations;

Note: deemed modified by Sec. 5 of RA 8369, the law w/c established the Family Courts.
However, under Sec. 17 of RA 8369, in areas where there are no FCs, the cases referred to in Sec. 5
of the law shall be adjudicated by the RTC.
 REGIONAL TRIAL COURTS: Jurisdiction
Exclusive Original Jurisdiction Over Civil Cases:
13
6. Cases not within the exclusive jurisdiction of any court, tribunal, person or body exercising
jurisdiction of any court, tribunal, person or body exercising judicial or quasi-judicial functions;

Note: This jurisdiction is often described as the “general” jurisdiction of the RTC making it a court
of “general jurisdiction”.

7. Civil actions and special proceedings falling within the exclusive original jurisdiction of the
Juvenile and Domestic Relations Court and of the Court of Agrarian Relations as now provided by
law; and

Note: Juvenile and Domestic Relations Court is subject to RA 8369, the law establishing Family
Courts

8. All other 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 P2M.
 REGIONAL TRIAL COURTS: Jurisdiction
Exclusive Original Jurisdiction Over Criminal Cases:
1. Criminal cases not within the
14 exclusive jurisdiction of any court,
tribunal, or body (Sec. 20, BP 1290
2. Criminal cases where the penalty
provided by law exceeds 6 years
imprisonment irrespective of the fine
3. In cases where the only penalty
provided by law is a fine, the RTCs have
jurisdiction if the amount of the fine
exceeds P4k (RA 7691)
4. In cases where none of the
accused are occupying positions
corresponding to Salary Grade 27
or higher, as prescribed in RA 6758,
or military and PNP officers
mentioned above, exclusive original
jurisdiction thereof shall be vested in
the proper RTC, MeTC, MTC &
MCTC, as the case may be, pursuant
to their respective jurisdictions as
provided in BP Blg. 129, as
amended (Sec. 2, RA 10660)
5. Violation of the provisions of the
Intellectual Property Code
6. Illegal recruitment cases as
penalized under RA 8042 as
amended by RA 10022
7. Complex Crimes
- Jurisdiction over the whole complex
crime must logically be lodged with
the trial court having jurisdiction to
impose the maximum & most
serious penalty imposable on an
offense forming the complex crime
- A complex crime must be prosecuted
integrally, as it were, and not split
into its component offenses & the
latter made the subject of multiple
informations possible brought in
different courts
 REGIONAL TRIAL COURTS: Jurisdiction
Concurrent Jurisdiction With:
15
Supreme Court (SC) Actions affecting ambassadors, other public
ministers, and consuls;
SC & Court of Appeals Petitions for quo warranto and habeas
(CA) corpus;
SC, CA & Sandiganbayan a. Petitions for certiorari, prohibition, and
mandamus, if they relate to an act of a
trial court, corporation board, officer, or
person (Sec. 4, Rule 65 as amended by
AM No. 07-7-12-SC dated 12/12/2007
b. Petitions for writ of amparo and writ of
habeas data
MeTC, MTC, MCTC Application for protection Order under
Section 10, RA 9282, unless there is a
Family Court in the residence of petitioner.
Exclusive Appellate Jurisdiction
Appellate jurisdiction over all cases
decided by MeTCs, MTCs, and
MCTCs in their respective
territorial jurisdictions;
Note: The decisions of the RTC in
the exercise of its appellate
jurisdiction shall be appealable by
petition for review to the Court of
Appeals. The appeal shall be given
due course only when the petition
shows prima facie that the lower
court has committed an error of fact
or law that would warrant a reversal
or modification of the decision or
judgment sought to be reviewed.
 REGIONAL TRIAL COURTS: Jurisdiction
16 Special Certain branches of RTC may be
Jurisdiction designated by the SC to handle
to Try Cases exclusively:
1. criminal cases,
2. juvenile and domestic relations cases
(Family Courts),
3. agrarian cases (Special Agrarian
Court),
4. urban and land reform cases which do
not fall under the jurisdiction of quasi-
judicial bodies and agencies, and/or
5. such other special cases as the SC
may determine in the interest of a
speedy and efficient administration of
justice.
Jurisdiction Over Intra-Corporate
Controversies
By virtue of Item 5.2 of Section 5 of The
Securities Regulation Code (RA 8799),
jurisdiction over cases enumerated in
Section 5 of PD 902-A, was transferred
from the SEC to the “Courts of general
jurisdiction or the appropriate RTC.” The
same provision also provided that the SC
may designate the RTC branches that
shall exercise jurisdiction over said cases,
 REGIONAL TRIAL COURTS: Special Jurisdiction
A. Family Courts 1. One or more of the accused is below 18 years if age but not less
17
than 9 years of age; when one or more of the victims is a minor
at the time of the commission of the offense
2. Involving juveniles if no preliminary investigation is required
3. Cases against minors cognizable under RA 9165
4. Violation of RA 7610 (Special Protection of Children Against
Child Abuse & Exploitation & Discrimination Act)
5. Violation of RA 9775 (Anti Child Pornography Act of 2009)
6. Violation of RA 9262 (Anti-Violence Against Women and their
Children Act of 2004)
B. Special Agrarian Court Original and exclusive jurisdiction over
1. all petitions for the determination of just compensation to
landowners, and
2. the prosecution of all criminal offenses under RA 6657
(Comprehensive Agrarian Reform law of 1988)
 SHARI’A DISTRICT COURTS: Jurisdiction
Exclusive Original Jurisdiction Over: Concurrent with Existing Civil Appellate Jurisdiction
18 Courts: Original Jurisdiction
(a) All cases involving custody, Over: (1) Shari'a District Courts
guardianship, legitimacy, paternity and (a) Petitions by Muslims for the shall have appellate
filiation arising under the Code of Muslim constitution of a family home, jurisdiction over all
Personal Laws of the Phil; change of name and commitment of cases tried in the
The decisions of the (c) Petitions for the declaration of absence an insane person to an asylum; Shari'a Circuit Courts
Shari'a District and death and for the cancellation or (b) All other personal and real within their territorial
Courts whether on correction of entries in the Muslim actions not mentioned in paragraph 1 jurisdiction.
appeal from the Registries mentioned in Title VI of Book (d) wherein the parties involved are
Two of the Code; Muslims except those for forcible (2) The Shari'a District
Shari'a Circuit Court (d) All actions arising from customary Court shall decide
or not shall be final entry and unlawful detainer, which
contracts in which the parties are shall fall under the exclusive original every case appealed to
WITHOUT Muslims, if they have not specified which jurisdiction of the Municipal Circuit it on the basis of the
PREJUDICE AND law shall govern their relations; and Court; and evidence and records
SHALL NOT affect (e) All petitions for mandamus, (c) All special civil actions for transmitted as well as
prohibition, injunction, certiorari, habeas interpleader or declaratory relief such memoranda,
the original and
corpus, and all other auxiliary writs and wherein the parties are Muslims or briefs or oral
appellate processes in aid of its appellate arguments as the
the property involved belongs
jurisdiction of the jurisdiction. parties may submit.
exclusively to Muslims.
Supreme Court as
provided in the
Constitution.
Art. 155, PD 1083 - Code of Muslim Personal Laws of the Philippines
 “
Moving on, we go now to the
next level in the hierarchy
which are the collegiate
courts

First off….

19
 COURT OF APPEALS (CA): Jurisdiction
20
CA is primarily designed as an appellate court that reviews the
determination of facts and law made by the trial courts.

It is collegiate in nature
- This nature ensures standpoints in the review of the actions of
the trial courts.

CA also has original jurisdiction over most special civil actions.

Unlike trial courts, its writs can have a nationwide scope.

It is competent to determine facts and ideally, should act on

constitutional issues that may not necessarily be novel unless
there are factual questions to determine.
 COURT OF APPEALS (CA): Jurisdiction
Original Jurisdiction Concurrent with: Exclusive Appellate Exclusive Appellate
21 Over: Jurisdiction Over: Jurisdiction Over:
1. Petition for certiorari, SC, 1. By ordinary appeal
prohibition, mandamus, Sandiganbayan, - Decision & final order
habeas corpus; RTC over petitions by the RTCs in the
3. Automatic Review of
for: exercise of its original
the decision of the RTC
2. Writ of amparo; jurisdiction, except
when the penalty imposed
1. Petition for those appealable to the
is death, reclusion
3. Habeas data; certiorari, SC or the
perpetual or life
prohibition, Sandiganbayan or the
imprisonment (mandatory)
4. Petition for freeze order mandamus, CTA
on any monetary habeas corpus;
instrument, property, or 2. By petition for review
proceedings relating to 2. Writ of amparo; - Decisions & final orders
or involving any rendered by the RTCs in
unlawful activity as 3. Habeas data the exercise of its
defined under Sec. 3 (j) appellate jurisdiction
of RA 9160 (AMLA) as under Rule 122 in relation
amended by RA 9194 to Rule 42 of the ROC
(AMLC)
 COURT OF TAX APPEALS (CTA): Jurisdiction
Exclusive appellate jurisdiction to review by appeal
22 1. Decisions of the Commissioner of Internal Revenue in cases involving disputed assessments, refunds of internal
revenue taxes, fees or other charges, penalties in relation thereto, or other matters arising under the National Internal
Revenue or other laws administered by the Bureau of Internal Revenue;
2. Inaction by the Commissioner of Internal Revenue in cases abovementioned where the NIRC provides a specific
period of action, in which case the inaction shall be deemed a denial;
3. Decisions, orders or resolutions of the RTC in local tax cases originally decided or resolved by them in the exercise
RA 9282 – of their original or appellate jurisdiction;
Expanding the 4. Decisions of the Commissioner of Customs in cases involving liability for customs duties, fees or other money
Jurisdiction of the charges, seizure, detention or release of property affected, fines, forfeitures or other penalties in relation thereto, or
CTA, Elevating Its other matters arising under the Customs Law or other laws administered by the Bureau of Customs;
5. Decisions of the Central Board of Assessment Appeals in the exercise of its appellate jurisdiction over cases
Rank to the Level of involving the assessment and taxation of real property originally decided by the provincial or city board of
Collegiate Court assessment appeals;
with Special 6. Decisions of the Secretary of Finance on customs cases elevated to him automatically for review from decisions of
Jurisdiction& the Commissioner of Customs which are adverse to the Government under Section 2315 of the Tariff and Customs
Enlarging Its Code;
Membership 7. Decisions of the Secretary of Trade and Industry, in the case of nonagricultural product, commodity or article, and
the Secretary of Agriculture in the case of agricultural product, commodity or article, involving dumping and
(03/30/2004) countervailing duties under Section 301 and 302, respectively, of the Tariff and Customs Code, and safeguard
measures under Republic Act No. 8800, where either party may appeal the decision to impose or not to impose said
duties.
 COURT OF TAX APPEALS (CTA): Jurisdiction
Exclusive original jurisdiction –
23 Criminal Offenses
Arising from violations of the
National Internal Revenue Code
or Tariff and Customs Code and
other laws administered by the
Bureau of Internal Revenue or the
Bureau of Customs: Provided,
however, That offenses or
felonies mentioned in this
paragraph where the principal
amount o taxes and fees,
exclusive of charges and
penalties, claimed is less than
One million pesos
(P1,000,000.00) or where there is
no specified amount claimed shall
be tried by the regular Courts and
the jurisdiction of the CTA shall
be appellate.
Exclusive appellate jurisdiction – Criminal Offenses
a. Over appeals from the judgments, resolutions or orders of the Regional
Trial Courts in tax cases originally decided by them, in their respected
territorial jurisdiction.
b. Over petitions for review of the judgments, resolutions or orders of the
Regional Trial Courts in the exercise of their appellate jurisdiction over tax
cases originally decided by the Metropolitan Trial Courts, Municipal Trial
Courts and Municipal Circuit Trial Courts in their respective jurisdiction.
c. Jurisdiction over tax collection cases
1. Exclusive original jurisdiction in tax collection cases involving final &
executory assessments for taxes, charges & penalties where the principal
amount is P1M & above exclusive of charges & penalties
2. Exclusive appellate jurisdiction in tax collection cases:
- Over appeals from judgments, resolutions or orders of RTC in tax collection
cases originally decided by them or
- in the exercise of RTC’s appellate jurisdiction over tax collection cases
originally decided by MTCs
 SANDIGANBAYAN: Jurisdiction
24
Sandiganbayan is a special court of the same
level as the CA and possessing all the inherent
power of a court of justice.

EO No. 14 & It is composed of a Presiding Justice & 8

14-A: Associate Justices who shall be appointed by
Sandiganbaya the President.
n’s
jurisdiction
over criminal Created pursuant to Section 1 of Presidential
& civil cases Decree No. 1606 (Law Creating a Special
relative to the Court to be Known as Sandiganbayan and for
ill-gotten Other Purposes)
wealth of the
Marcoses &
their cronies.

25
EO No. 1: Cases of
recovery & sequestration
of ill-gotten wealth
amassed by the
Marcoses, their relatives,
etc by taking undue
advantage of their public
office &/or using their
powers, authority,
influence or
relationships
EO No. 2: Pertains to
the ill-gotten wealth in
the form of estates &
real properties in the
Philippines and abroad
SANDIGANBAYAN: Jurisdiction
Exclusive Original Jurisdiction Over Cases:
1. Violations of RA No. 3019 (Anti-Graft & Corrupt Practices
Act, RA No. 1379, and Chapter II, Sec. 2, Title VII, Book II
of the RPC, where one or more of the accused are officials
occupying the positions classified as Salary Grade 27 in the
government, whether in a permanent, acting or interim
capacity, at the time of the commission of the offense;
2. Other offenses or felonies whether simple or complexed with
other crimes committed by the public officials & employees
mentioned in relation to their office;
3. Civil and criminal cases filed pursuant to and in connection
with EO Nos. 1, 2, 14 and 14-A, issued in 1986 wherein the
information alleges any damage to the government or any
bribery arising from the same or closely related transactions
or acts exceeding P1M, otherwise it shall fall under the
exclusive original jurisdiction of the RTC, and the jurisdiction
of Snadiganbayan will be appellate
Exclusive Original Jurisdiction
Over:
4. Petitions for the issuance of the
writs of mandamus, prohibition,
certiorari, habeas corpus, injunctions
& other ancillary writs and processes
in aid of its appellate jurisdiction and
over petitions of similar nature,
including quo warranto, arising or that
may arise in cases filed under EO 1, 2,
14 & 14-A, issued in 1986 provided
that the jurisdiction over these
petitions shall not be exclusive of the
SC.
 SANDIGANBAYAN: Jurisdiction
Concurrent with SC, CA & RTC Exclusive Appellate Jurisdiction
26
1. Petitions for writ of amparo and
writ of habeas data when action
concerns public data files of Over final judgment, resolutions, or
government offices orders of RTCs whether in the exercise of
their own original jurisdiction or their
2. Petitions for certiorari, appellate jurisdiction.
prohibition, and mandamus,
relating to an act or omission of
MTC, corporation, board,
officer, or person
 “
Finally, we will now discuss
the “highest tribunal”

SC

27
 SUPREME COURT (SC): Jurisdiction
28 SC is a constitutional court as it was
created by a direct constitutional
provision (Sec. 1, Art. VIII,
Constitution of the Philippines).
Highest tribunal
Fundamentally a court of appellate
jurisdiction but it may also be a court
of original jurisdiction in some cases.
Fundamentally a court of appellate
jurisdiction but it may also be a court
or original jurisdiction in some cases.
The SC may disregard the doctrine of hierarchy of courts if
warranted by the nature and importance of the issues raised in
the interest of speedy justice and to avoid future litigations.
In relation to cases filed with the SC, a direct resort to it was
allowed in certain cases, like:
1. When the are special & important reasons clearly stated in
the petition;
2. When dictated by public welfare & the advancement of
public policy;
3. When demanded by the broader interest of justice;
4. When the challenged orders were patent nullities;
5. When analogous exceptional & compelling circumstances
called for & justified the immediate & direct handling by the
Court;
6. When there are genuine issues of constitutionality that must
be addressed at the most immediate time.
 SUPREME COURT (SC): Jurisdiction
Exclusive Original Jurisdiction
29
Over (Sec. 5, Par. (1), Article VIII,
1987 Constitution
1. Cases affecting ambassadors,
other public ministers, and
consuls; and
2. Petitions for certiorari,
prohibition, mandamus, quo
warranto, and habeas corpus
Concurrent Jurisdiction with CA,
Sandiganbayan & RTC Over:
1. Petitions for certiorari,
prohibition, mandamus, habeas
corpus, amparo and data
Review decisions of the lower courts (Sec. 5, Par. (2),
Article VIII, 1987 Constitution
Review, revise, reverse, modify, or affirm on appeal or
certiorari, as the law or the Rules of Court may provide, final
judgments and orders of lower courts in:
(a) All cases in which the constitutionality or validity of any
treaty, international or executive agreement, law, presidential
decree, proclamation, order, instruction, ordinance, or
regulation is in question.
(b) All cases involving the legality of any tax, impost,
assessment, or toll, or any penalty imposed in relation thereto.
(c) All cases in which the jurisdiction of any lower court is in
issue.
(d) All criminal cases in which the penalty imposed is
reclusion perpetua or higher.
(e) All cases in which only an error or question of law is
involved.
30

Thank
you!