Marinas, Rodeleine Grace C.

Case no. 22. Orion Water District v. GSIS G.R. 195382 June 15, 2016

Facts:

The instant case stemmed from a Complaint for Collection of Sum of Money and Damages filed
on April 4, 2006 by the Government Service Insurance System (GSIS) before the Regional Trial
Court (RTC) of Pasay City against OWD, a local water district organized as a government-
owned and controlled corporation (GOCC), and its officers. GSIS alleged that OWD and its
officers failed and refused to pay, remit or deliver the employees' personal share in the premiums
of their life and retirement policies covering the period of July 1993 to July 31, 2000, amounting
to Five Hundred Fifty-One Thousand Four Hundred Seven Pesos and Sixteen Centavos
(P551,407.16). It averred that it repeatedly demanded the payment of said arrearages from OWD,
through its Manager, who received the last demand letter on November 21, 2002. Despite receipt
of the demand letter, however, OWD failed to remit its premium arrearages On March 13, 2007,
OWD filed a Motion to Dismiss alleging that the RTC has no jurisdiction over the subject matter
of the case. It asseverated that since GSIS and OWD are both GOCCs, jurisdiction over disputes
or controversies between them lies with the Secretary of Justice, pursuant to Sections 66 to
70, Chapter 14, Book IV of Executive Order (E.O.) No. 292.

Ruling of the RTC

On March 28, 2008, the RTC issued an Order9 denying the motion to dismiss for lack of merit. It
held, as follows:

After this Court perused the arguments of both parties, this Court finds the motion unmeritorious.

The defendants failed to even allege that they are disputing or controverting the claim filed by
the [GSIS], or that the dispute, claim or controversy between the parties arises from the
interpretation or application of the statutes, contracts or agreements involved in this case.

WHEREFORE, the Motion is Denied.

On May 22, 2008, OWD and its officers filed a Motion for Reconsideration11 reiterating their
claim of lack of jurisdiction of the RTC. In an Order12 dated June 27, 2008, the RTC denied the
said motion

Ruling of the CA

On October 14, 2010, the CA rendered its Decision affirming the challenged orders of the RTC

Issue: Whether the RTC of Pasay City has jurisdiction over the subject matter of the case.

Ruling:
The Court finds the petition unmeritorious.

"Basic as a hornbook principle is that jurisdiction over the subject matter of a case is conferred
by law and determined by the allegations in the complaint which comprise a concise statement of
the ultimate facts constituting the plaintiff's cause of action." A reading of the complaint filed by
GSIS shows that it is aimed at recovering the premium arrearages of OWD on the life and
retirement policies of its employees which by law is supposed to deduct from the salaries of the
employees concerned and remit to GSIS accordingly.

It is well to remember that membership in the GSIS is compulsory for all employees receiving
compensation who have not reached the compulsory retirement age, irrespective of employment
status. Pursuant to this, Section 6(b) of R.A. No. 8291 imposes a positive duty on the employer to
deduct and remit the contributions to the GSIS. In case of delayed remittance, Section 7 of the
law charges interest on the unremitted amount at the rate of not less than two percent (2%) which
shall be shouldered by the employer. Continued refusal of the employer to remit contributions
gives rise to a cause of action on the part of GSIS to institute the necessary action in the
appropriate court or tribunal to recover unremitted contributions. As correctly held by the CA,
the GSIS properly instituted the complaint with the RTC, which has the jurisdiction in civil cases
where the demand for sums of money or value of property exceeds P300,000.00 in the provinces,
or P400,000.00 in Metro Manila.

Case no. 23. Concorde Condominium Inc. v. Augusto H. Baculio G.R. 203678 February 17,
2016

Facts:

On April 16, 2012, petitioner Concorde Condominium, Inc., by itself and comprising the Unit
Owners of Concorde Condominium Building, filed with the Regional Trial Court of Makati City
a Petition for Injunction against respondents New PPI Corporation and its President Augusto H.
Baculio

Petitioner seeks:

(1) to enjoin respondents Baculio and New PPI Corporation from misrepresenting to the public,
as well as to private and government offices/agencies, that they are the owners of the disputed
lots and Concorde Condominium Building, and from pushing for the demolition of the building
which they do not even own;

(2) to prevent respondent Asian Security and Investigation Agency from deploying its security
guards within the perimeter of the said building; and

(3) to restrain respondents Engr. Morales, Supt. Perdigon and F/C Supt. Laguna from responding
to and acting upon the letters being sent by Baculio, who is a mere impostor and has no legal
personality with regard to matters concerning the revocation of building and occupancy permits,
and the fire safety issues of the same building. It also prays to hold respondents solidarily liable
for actual damages, moral damages, exemplary damages, attorney's fees, litigation expenses and
costs of suit

The case was docketed as Civil Case No. No. 12-309 and raffled to the Makati RTC, Branch
149, which was designated as a Special Commercial Court

Meanwhile, respondents Baculio and New PPI Corporation filed an Urgent Motion to Re-Raffle
dated April 25, 2012, claiming that it is a regular court, not a Special Commercial Court, which
has jurisdiction over the case. Respondents claimed that the petition seeks to restrain or compel
certain individuals and government officials to stop doing or performing particular acts, and that
there is no showing that the case involves a matter embraced in Section 5 of Presidential Decree
(P.D.) No. 902-A, which enumerates the cases over which the SEC [now the RTC acting as
Special Commercial Court pursuant to Republic Act (R.A.) No. 8799] exercises exclusive
jurisdiction. They added that petitioner failed to exhaust administrative remedies, which is a
condition precedent before filing the said petition.

In an Order dated June 28, 2012, the RTC dismissed the case for lack of jurisdiction. It noted that
by petitioner's own allegations and admissions, respondents Baculio and New PPI Corporation
are not owners of the two subject lots and the building. Due to the absence of intra-corporate
relations between the parties, it ruled that the case does not involve an intra-corporate
controversy cognizable by it sitting as a Special Commercial Court. It also held that there is no
more necessity to discuss the other issues raised in the motion to dismiss, as well as the motion
to vacate order, for lack of jurisdiction over the case.

Issue:

Whether Branch 149 of the Makati RTC, a designated Special Commercial Court, erred in
dismissing the petition for injunction with damages for lack of jurisdiction over the subject
matter.

Ruling:

The Court is guided by the rule "that jurisdiction over the subject matter of a case is conferred by
law and determined by the allegations in the complaint which comprise a concise statement of
the ultimate facts constituting the plaintiffs cause of action. The nature of an action, as well as
which court or body has jurisdiction over it, is determined based on the allegations contained in
the complaint of the plaintiff, irrespective of whether or not the plaintiff is entitled to recover
upon all or some of the claims asserted therein. The averments in the complaint and the character
of the relief sought are the ones to be consulted. Once vested by the allegations in the complaint,
jurisdiction also remains vested irrespective of whether or not the plaintiff is entitled to recover
upon all or some of the claims asserted therein." As a rule, actions for injunction and damages lie
within the jurisdiction of the RTC, pursuant to Section 19 of Batas Pambansa Blg. 129, otherwise
known as the judiciary Reorganization Act of 1980, as amended by R.A. 7691. Jurisdiction of
the SEC over intra-corporate cases was transferred to Courts of general jurisdiction or the
appropriate Regional Trial Court when R.A. No. 8799 took effect on August 8, 2000. Section 5.2
of R.A. No. 8799 provides:
SEC. 5.2 The Commission's jurisdiction over all cases enumerated under Section 5 of
Presidential Decree No. 902-A is hereby transferred to the Courts of general jurisdiction or the
appropriate Regional Trial Court: Provided, that the Supreme Court in the exercise of its
authority may designate the Regional Trial Court branches that shall exercise jurisdiction over
these cases. The Commission shall retain jurisdiction over pending cases involving intra-
corporate disputes submitted for final resolution which should be resolved within one (1) year
from the enactment of this Code. The Commission shall retain jurisdiction over pending
suspension of payments/rehabilitation cases filed as of 30 June 2000 until finally disposed.

Case no. 24. Spouses Erorita v. Spouses Dumlao G.R. 195477 January 25, 2016

Facts:

Spouses Antonio and Ligaya Dumlao (Spouses Dumlao) are the registered owners of a parcel of
landlocated at Barangay San Mariano, Roxas, Oriental Mindoro, and covered by TCT No. T-
53000 in which SanMariano Academy structures are built. On April 25, 1990, Spouses Dumlao
bought the property in an extrajudicial foreclosure sale whenSpouses Herminio and Editha
Erorita (Spouses Erorita) former owners, failed to redeem it. With the consentof Spouses
Dumlao, it however allowed Spouses Erorita to continue to operate the school and to appoint
Hernan and Susan Erorita as the school’s administrators.On December 16, 2002, Spouses
Dumlao asked the petitioners to vacate the property for they hadfailed to pay monthly rent of
Twenty Thousand Pesos (P20,000.00) since 1990. The Spouses Erorita howevercountered that
the Dumlaos allowed them to continue to run the school without rental out of goodwill
andfriendship.On March 4, 2004, the Spouses Dumlao filed a complaint for recovery of
possession before theRegional Trial Court (RTC) against the defendants Hernan, Susan, and the
Spouses Erorita.On June 4, 2007, the RTC ruled in favour of spouses Dumlao. It ordered the
defendants (1) toimmediately vacate the property and turn it over to the Spouses Dumlao, and (2)
to pay accumulated rentals, damages, and attorney’s fees. The RTC also prohibited the
defendants from accepting enrolees to the San Mariano Academy.The defendants Erorita then
appealed to the CA arguing that the complaint is a case for unlawful detainer in which the RTC
had no jurisdiction over the subject matter of the case.

Issue:

Whether the RTC has jurisdiction

Ruling:

The petition is partly meritorious. We hold that the MTC had jurisdiction

Jurisdiction is based on the allegations in the complaint.

On the first issue, the allegations in the complaint determine the nature of an action and
jurisdiction over the case. Jurisdiction does not depend on the complaint’s caption. Nor is
jurisdiction changed by the defenses in the answer; otherwise, the defendant may easily delay a
case by raising other issues, then, claim lack of jurisdiction. To make a case for unlawful
detainer, the complaint must allege that: (a) initially, the defendant lawfully possessed the
property, either by contract or by plaintiff’s tolerance; (b) the plaintiff notified the defendant that
his right of possession is terminated; (c) the defendant remained in possession and deprived
plaintiff of its enjoyment; and (d) the plaintiff filed a complaint within one year from the last
demand on defendant to vacate the property. A complaint for accion publiciana or recovery of
possession of real property will not be considered as an action for unlawful detainer if any of
these special jurisdictional facts is omitted.

A review of the complaint shows that: (a) the owners, Spouses Dumlao, agreed to allow the
petitioners to continue operating the school on the disputed property; (b) in a demand letter dated
February 12, 2004, the Spouses Dumlao told the petitioners to pay and/or vacate the property; (c)
the respondents refused to vacate the property; and (d) the Spouses Dumlao filed the complaint
(March 4, 2004) within a year from the last demand to vacate (February 12, 2004).
Thus, although the complaint bears the caption "recovery of possession," its allegations contain
the jurisdictional facts for an unlawful detainer case. Under RA 7691, an action for unlawful
detainer is within the MTC’s exclusive jurisdiction regardless of the property’s assessed value.
The CA incorrectly applied our ruling in Barbosa. In that case, the complaint did not state that (i)
possession was unlawfully withheld and (ii) the complaint was filed within a year from the last
demand. Because these special jurisdictional facts for an unlawful detainer case were lacking, we
held that the case should be accion publiciana over which the RTC has jurisdiction
In the present case, however, the complaint clearly contained the elements of an unlawful
detainer case. Thus, the case should have been filed with the MTC. The RTC had no jurisdiction
over this case.

Since a decision rendered by a court without jurisdiction is void, the RTC’s decision is void