JURISDICTION

Bernabe Navida et al vs Hon. Teodoro Dizon et al

The rule is settled that jurisdiction over the subject matter
of a case is conferred by law and is determined by the
allegations in the complaint and the character of the relief
sought, irrespective of whether the plaintiffs are entitled to
all or some of the claims asserted therein. Once vested by
law, on a particular court or body, the jurisdiction over the
subject matter or nature of the action cannot be dislodged
by anybody other than by the legislature through the
enactment of a law.
It may also be pertinently stressed that "jurisdiction" is
different from the "exercise of jurisdiction." Jurisdiction
refers to the authority to decide a case, not the orders or
the decision rendered therein. Accordingly, where a court
has jurisdiction over the persons of the defendants and the
subject matter, as in the case of the courts a quo, the
decision on all questions arising therefrom is but an
exercise of such jurisdiction. Any error that the court may
commit in the exercise of its jurisdiction is merely an error
of judgment, which does not affect its authority to decide
the case, much less divest the court of the jurisdiction over
the case.
LBP v. Villegas
A branch of an RTC designated as a Special Agrarian
Court for a province has the original and exclusive
jurisdiction over all petitions for the determination of just
compensation in that province. By special jurisdiction,
Special Agrarian Courts exercise power in addition to or
over and above the ordinary jurisdiction of the RTC, such
as taking cognizance of suits involving agricultural lands
located outside their regular territorial jurisdiction, so long
as they are within the province where they sit as Special
Agrarian Courts.
Celia S. Vda. De Herrera v. Emelita bernardo
It is axiomatic that the jurisdiction of a tribunal, including a
quasi-judicial officer or government agency, over the
nature and subject matter of a petition or complaint is
determined by the material allegations therein and the
character of the relief prayed for, irrespective of whether
the petitioner or complainant is entitled to any or all such
reliefs.
Since the COSLAP has no jurisdiction over the action, all
the proceedings therein, including the decision rendered,
are null and void. A judgment issued by a quasi-judicial
body without jurisdiction is void. It cannot be the source of
any right or create any obligation. All acts performed
pursuant to it and all claims emanating from it have no
legal effect. Having no legal effect, the situation is the
same as it would be as if there was no judgment at all. It
leaves the parties in the position they were before the
proceedings.
Sps. Eulogia and Ramon Manila vs Sps. Ederlinda and
Daniel Manzo
Lack of jurisdiction as a ground for annulment of judgment
refers to either lack of jurisdiction over the person of the
defending party or over the subject matter of the claim. In
a petition for annulment of judgment based on lack of
jurisdiction, petitioner must show not merely an abuse of
jurisdictional discretion but an absolute lack of jurisdiction.
Lack of jurisdiction means absence of or no jurisdiction,
that is, the court should not have taken cognizance of the
petition because the law does not vest it with jurisdiction
over the subject matter. Jurisdiction over the nature of the
action or subject matter is conferred by law.
Such erroneous grant of relief to the defendants on
appeal, however, is but an exercise of jurisdiction by the
RTC. Jurisdiction is not the same as the exercise of

jurisdiction. As distinguished from the exercise of

jurisdiction, jurisdiction is the authority to decide a cause,
and not the decision rendered therein. The ground for
annulment of the decision is absence of, or no, jurisdiction;
that is, the court should not have taken cognizance of the
petition because the law does not vest it with jurisdiction
over the subject matter.
EDNA DIAGO LHUILLIER v BRITISH AIRWAYS
Since the Warsaw Convention applies in the instant case,
then the jurisdiction over the subject matter of the action is
governed by the provisions of the Warsaw Convention.
Under Article 28(1) of the Warsaw Convention, the plaintiff
may bring the action for damages before:
1. the court where the carrier is domiciled;
2. the court where the carrier has its principal place of
business;
3. the court where the carrier has an establishment by
which the contract has been made; or
4. the court of the place of destination.
We thus find that the RTC of Makati correctly ruled that it
does not have jurisdiction over the case filed by the
petitioner.
Heirs of Santiago Nisperos v. Nisperos-Ducusin
In one of the cases decided by SC, it was held that there
must be a tenancy relationship between the parties for the
DARAB to have jurisdiction over a case. It is essential to
establish all of the following indispensable elements, to wit:
(1) that the parties are the landowner and the tenant or
agricultural lessee; (2) that the subject matter of the
relationship is an agricultural land; (3) that there is consent
between the parties to the relationship; (4) that the
purpose of the relationship is to bring about agricultural
production; (5) that there is personal cultivation on the part
of the tenant or agricultural lessee; and (6) that the harvest
is shared between the landowner and the tenant or
agricultural lessee. In the instant case, petitioners, as
supposed owners of the subject property, did not allege in
their complaint that a tenancy relationship exists between
them and respondent. In fact, in their complaint, they
described respondent as a "ward" of one of the co-owners,
Maria, who is "not a bona fide beneficiary, she being not
engaged in farming because she was still a minor" at the
time the VLT was executed.
It is axiomatic that the jurisdiction of a tribunal, including a
quasi-judicial officer or government agency, over the
nature and subject matter of a petition or complaint is
determined by the material allegations therein and the
character of the relief prayed for, irrespective of whether
the petitioner or complainant is entitled to any or all such
reliefs. Jurisdiction over the nature and subject matter of
an action is conferred by the Constitution and the law, and
not by the consent or waiver of the parties where the court
otherwise would have no jurisdiction over the nature or
subject matter of the action. Nor can it be acquired
through, or waived by, any act or omission of the parties.
Moreover, estoppel does not apply to confer jurisdiction to
a tribunal that has none over the cause of action. The
failure of the parties to challenge the jurisdiction of the
DARAB does not prevent the court from addressing the
issue, especially where the DARABs lack of jurisdiction is
apparent on the face of the complaint or petition.
While it is true that the PARAD and the DARAB (which was
upheld by the CA) thoroughly discussed in their respective
decisions the issues pertaining to the validity of the VLT
and the OCT/CLOA issued to respondent, the fact that
they are bereft of jurisdiction to resolve the same prevents
this Court from resolving the instant petition on its merits.
The doctrine of primary jurisdiction does not allow a court
to arrogate unto itself authority to resolve a controversy,
the jurisdiction over which is initially lodged with an

administrative body of special competence. To assume the

power is to short-circuit the administrative process, which
has yet to run its regular course. The DAR must be given a
chance to correct its administrative and procedural lapses
in the issuance of the CLOA. Moreover, it is in a better
position to resolve the particular issue at hand, being the
agency possessing the required expertise on the matter
and authority to hear the same.
DY vs. HON. GINA M. BIBAT- PALAMOS
Under the principle of hierarchy of courts, direct recourse
to this Court is improper because the Supreme Court is a
court of last resort and must remain to be so in order for it
to satisfactorily perform its constitutional functions, thereby
allowing it to devote its time and attention to matters within
its exclusive jurisdiction and preventing the overcrowding
of its docket. Nonetheless, the invocation of this Courts
original jurisdiction to issue writs of certiorari has been
allowed in certain instances on the ground of special and
important reasons clearly stated in the petition, such as,(1)
when dictated by the public welfare and the advancement
of public policy; (2) when demanded by the broader
interest of justice; (3) when the challenged orders were

patent nullities; or (4) when analogous exceptional and

compelling circumstances called for and justified the
immediate and direct handling of the case.
This Court is not unaware of the doctrine of immutability of
judgments. When a judgment becomes final and
executory, it is made immutable and unalterable, meaning
it can no longer be modified in any respect either by the
court which rendered it or even by this Court. Its purpose
is to avoid delay in the orderly administration of justice and
to put an end to judicial controversies. Even at the risk of
occasional errors, public policy and sound practice dictate
that judgments must become final at some point. As with
every rule, however, this admits of certain exceptions.
When a supervening event renders the execution of a
judgment impossible or unjust, the interested party can
petition the court to modify the judgment to harmonize it
with justice and the facts.32 A supervening event is a fact
which transpires or a new circumstance which develops
after a judgment has become final and executory. This
includes matters which the parties were unaware of prior
to or during trial because they were not yet in existence at
that time