Salvador et al.

are occupants of a parcel of land situated at

Jurisdiction Exercise of Venue Juan Luna Street, Gagalangin, Tondo. They have been in
Jurisdiction open and notorious possession of the subject property for
Authority of the Exercise of the Geographical more than thirty years, and constructed in good faith their
court to hear, try court’s authority; area where an houses and other improvements on the property. By virtue of
and decide a Presupposes that action is to be a transfer certificate of title, defendant Patricia, Inc. is
case the court already filed and tried threatening to evict the plaintiffs from the property.
has jurisdiction
They filed a complaint with two causes of action: injunction
Establishes a Establishes and quieting of title to determine who owns the property. The
relationship relation between City of Manila filed a Complaint-in-Intervention, claiming to be
between the plaintiff and the owner of such land.
Court and the defendant
subject matter Two of the commissioners reported that the land belonged to
If a court without If the court has the City of Manila. Thus, the RTC granted the petition,
jurisdiction jurisdiction and permanently enjoining Patricia, Inc. from doing any act that
decides a case, commits an error would evict the former from their respective premises, and
the decision is in its decision, from collecting any rentals from them. On appeal, the CA,
VOID. the decision is reversed such judgment dismissed the complaint. The CA
VALID. declared that the petitioners were without the necessary
Remedy: interest, either legal or equitable title, to maintain a suit for
Annulment of Remedy: quieting of title.
Judgment or Appeal
Petition for ISSUES:
Certiorari Whether or not the RTC had jurisdiction over the complaint
involving causes of action for injunction and quieting of title
Conferred by law Presupposes that May be
the court already conferred by RULING:
has jurisdiction waiver or No.
over the subject agreement of
matter, parties, the parties The power of a court to hear and decide a controversy is
res, issues. called its jurisdiction. Jurisdiction is to be distinguished from
its exercise. When there is jurisdiction over the person and
subject matter, the decision of all other questions arising in
Mangubat v. Morga-Seva the case is but an exercise of that jurisdiction. The test of
FACTS: jurisdiction is whether or not the court or tribunal had the
Mangubat (petitioner) filed a Complaint for Specific power to enter on the inquiry, not whether or not its
Performance against Moga-Seva (respondent) over a dispute conclusions in the course thereof were correct, for the
over a parcel of land. The two parties later entered into a power to decide necessarily carries with it the power to
Compromise Agreement which was approved by the RTC on decide wrongly as well as rightly.
February 23, 2001. In the said agreement, Morga-Seva was
to pay a total of P72,600 (amount paid by Mangubat for Section 19 of Batas Pambansa Blg. 129 confers the exclusive
Morga-Seva’s loan obligation with DBP) plus P5,000 original jurisdiction of the RTC in civil cases. Based on such
attorney’s fees to Mangubat on or before June 30, 2001; and provision, the RTC had jurisdiction over the cause of action
upon payment, Mangubat was to transfer the title over the for injunction because it was one in which the subject of the
disputed land to Morga-Seva. As fate would have it, Mangubat litigation was incapable of pecuniary estimation.
refused to surrender the said property as agreed and instead,
he filed with the same RTC a Motion to Declare the Amicable However, the same was not true in the case of the cause of
Settlement Null and Void which was subsequently denied. action for the quieting of title, which had the nature of a real
Morga-Seva filed a Motion for Execution of Specific Acts action. Jurisdiction over a real action is determined based on
praying that Mangubat be compelled to surrender the title of the allegations in the complaint of the assessed value of the
the subject property; this was granted by the RTC. Aggrieved, property involved. The complaint of the petitioners did not
Mangubat filed a Petition for Annulment of Final Order with contain any averment of the assessed value of the
the CA, arguing that the RTC had already lost jurisdiction over property. Such failure left the trial court bereft of any
the case when its February 23, 2001 Decision became final; basis to determine which court could validly take
hence, it no longer had the authority to issue the Order cognizance of the cause of action for quieting of title. The
granting the Motion for Execution of Specific Acts. silence of the complaint on such value is ground to dismiss
the action for lack of jurisdiction because the trial court is not
ISSUE: given the basis for making the determination. Thus, the RTC
Did the RTC have jurisdiction to grant the Motion for Execution did not have jurisdiction over the complaint.
of Specific Acts?
WHEREFORE, the Court AFFIRMS the decision by the Court
RULING: of Appeals.
Yes. It is settled that once jurisdiction has been acquired, it is
not lost until the court shall have disposed of the case in its Venue
entirety. Here, Mangubat confused lack of jurisdiction with the Davao Light & Power Co. v. CA
error in the exercise of jurisdiction. Jurisdiction is not the same Venue and jurisdiction are entirely distinct matters.
as the exercise of jurisdiction. As distinguished from the Jurisdiction may not be conferred by consent or waiver upon
exercise of jurisdiction, jurisdiction is the authority to a court which otherwise would have no jurisdiction over the
decide a case, and not the decision rendered therein. subject-matter of an action; but the venue of an action as fixed
Where there is jurisdiction over the person and the by statute may be changed by the consent of the parties and
subject matter, the decision on all other questions arising an objection that the plaintiff brought his suit in the wrong
in the case is but an exercise of such jurisdiction. And the county may be waived by the failure of the defendant to make
errors which the court may commit in the exercise of a timely objection. In either case, the court may render a valid
jurisdiction are merely errors of judgment which are the proper judgment. Rules as to jurisdiction can never be left to the
subject of an appeal. The error raised by [Mangubat] pertains consent or agreement of the parties, whether or not a
to the trial court's exercise of its jurisdiction, not its lack of prohibition exists against their alteration.
authority to decide the case.
FACTS:
TN: The court does not lose its jurisdiction when the case A complaint for damages amounting to Php11M was filed by
attains finality. It still has the jurisdiction to enforce the same. Davao Light & Power (plaintiff) against Francisco Tesorero
(defendant) before the RTC of Cebu City.
Salvador v. Patricia Inc.
FACTS: In its complaint, plaintiff DLP alleged that Banilad, Cebu City
is its principal place of business and which for purposes of
venue, is considered as its residence. Defendant Tesorero, in
his answer, filed a motion to dismiss claiming that (a) the
complaint did not state a cause of action; (b) the plaintiff's
claim has been extinguished or otherwise rendered moot and
academic; (c) there was non-joinder of indispensable parties;
and (d) venue was improperly laid.
The complaint was dismissed through a resolution issued by
the RTC of Cebu City on the ground of improper venue. The
trial court is of the opinion that the principal office and the
residence of the plaintiff is in Davao City for purposes of venue
and not in Cebu City. It considered the following:
First, defendant Tesorero alleged and submitted in his motion
that the principal office of the plaintiff is at "163-165 P. Reyes
Street, Davao City as borne out by the Contract of Lease and
another Contract of Lease of Generating Equipment executed
by the plaintiff with the NAPOCOR. This representation barred
the plaintiff from denying the same.
Also, another factor considered by the Courts in deciding
controversies regarding venue are considerations of judicial
economy and administration, as well as the convenience of
the parties for which the rules of procedure and venue were
formulated.
ISSUE:
Whether or not the trial court erred it its decision that the
principal office of the plaintiff is in Davao City and not in Cebu
City for purposes of venue for filing the complaint?
RULING:
Yes, the principal office and residence of the plaintiff for
purposes of venue for filing the complaint is in Cebu City. A
corporation, like the plaintiff in this case, has no residence in
the same sense as that of a natural person. But for practical
purposes, a corporation is in a metaphysical sense a
resident of the place where its principal office is located
as stated in the articles of incorporation (Cohen v. Benguet
Commercial Co., Ltd., 34 Phil. 526 [1916] Clavecilla Radio
System v. Antillo, 19 SCRA 379 [1967]). The Corporation
Code precisely requires each corporation to specify in its
articles of incorporation the place where the principal office of
the corporation is to be located which must be within the
Philippines for purposes of fixing the residence of a
corporation in a definite place. As decided in Clavecilla Radio
System v. Antillon, the Court explained why actions cannot be
filed against a corporation in any place where the corporation
maintains its branch offices. The Court ruled that to allow an
action to be instituted in any place where the corporation has
branch offices, would create confusion and work untold
inconvenience to said entity. It is as well not allowed for a
corporation to file personal actions in a place other than its
principal place of business unless such a place is also the
residence of a co-plaintiff or a defendant. In the case at bar,
amended articles of incorporation and by-laws provided that
its principal office is in Cebu City. An action for damages is a
personal action, which venue is determined pursuant to Rule
4, Section 2 of the Rules of Court, which states:
All other actions may be commenced and tied
where the plaintiff or any of the principal
plaintiffs resides, or where the defendant or any
of the principal defendants resides, or in the
case of a non-resident defendant where he may
be found, at the election of the plaintiff.
Clearly, the defendant is not a party to any of the contracts
presented before the Court, as these contracts are contracted
between the plaintiff and the NAPOCOR. Also, the argument
that the allegation or representation made by the plaintiff in
either the complaints or answers it filed in several civil cases
that its residence is in Davao City should estop it from filing
the damage suit before the Cebu courts is without merit.
Besides, there is no showing that the defendant is a party in
those civil cases or that he relied on such representation by
the plaintiff.
Kinds of Jurisdiction
Original and appellate jurisdiction
A court is one with original jurisdiction when actions or
proceedings are originally filed with it. A court is one with
appellate jurisdiction when it has the power of review over the
decisions or orders of a lower court.
MeTCs, MCTCs and MTCs are courts of original jurisdiction
without appellate jurisdiction.
RTC is likewise a court of original jurisdiction with respect to
cases originally filed with it; and appellate court with respect
to cases decided by MTCs within its territorial
jurisdiction. (Sec. 22, BP 129).
CA is primarily a court of appellate jurisdiction with
competence to review judgments of the RTCs and specified
quasi-judicial agencies (Sec. 9[3], BP 129).
It is also a court of original jurisdiction with respect to cases
filed before it involving issuance of writs of certiorari,
mandamus, quo warranto, habeas corpus, and
prohibition. CA is a court of original and exclusive jurisdiction
over actions for annulment of judgments of RTCs (Sec. 9
[1],[2], BP 129).
The SC is fundamentally a court of appellate jurisdiction but it
may also be a court of original jurisdiction over cases affecting
ambassadors, public ministers and consuls, and in cases
involving petitions for certiorari, prohibition and mandamus
(Sec. 5[1], Art. VIII, Constitution).
The Supreme Court en banc is not an appellate court to which
decisions or resolutions of a division of the Supreme Court
may be appealed.
Exclusive and Concurrent Jurisdiction
Exclusive – means that the case can only be filed with that
particular court to the exclusion of others. (e.g. cases for
Ejectment can only be filed with the MTC; actions for specific
performance can only be filed with the RTC)
Concurrent – multiple courts have jurisdiction over the case;
doctrine of hierarchy of courts will now operate. (e.g. the SC,
CA, and RTC have concurrent jurisdiction over petitions for
certiorari filed against MTC decisions)
General and Special Jurisdiction
Courts of general jurisdiction are those with competence to
decide on their own jurisdiction and to take cognizance of all
cases, civil and criminal, of a particular nature. Courts of
special (limited) jurisdiction are those which have only a
special jurisdiction for a particular purpose or are clothed with
special powers for the performance of specified duties beyond
which they have no authority of any kind.
A court may also be considered general if it has the
competence to exercise jurisdiction over cases not falling
within the jurisdiction of any court, tribunal, person or body
exercising judicial or quasi-judicial functions. It is in the
context that the RTC is considered a court of general
jurisdiction.
Note: the jurisdiction of the RTC is not diminished because of
its designation as a special court.
 The Supreme Court has held that despite its
designation as a Family Court, a Regional Trial
Court remains possessed of authority as a
court of general jurisdiction to resolve the
constitutionality of a statute. (Garcia v. Drilon, 25
June 2013)
 A special commercial court is still a court of general
jurisdiction and can hear and try a non-commercial
case. [Concorde Condominium Inc. v. Baculio, 17
Feb 2016, Peralta, J.].
 If an intra-corporate case is raffled to a regular
branch of RTC, the error is only a matter of
procedure rather than jurisdiction. Remedy is to
refer the case to the Executive Judge for re-
docketing.
Doctrine of Exhaustion of Administrative Remedies
when the law provides for a remedy against a certain action
of an administrative board, body, or officer, relief to the courts
can be made only after exhausting all remedies provided
therein. It is settled that the non-observance of the doctrine of
exhaustion of administrative remedies results in lack of cause
of action, which is one of the grounds in the Rules of Court
justifying the dismissal of the complaint.
TN: Noncompliance will lead to DISMISSAL of the case
Doctrine of Primary Jurisdiction possession issued by another RTC. The principle also bars a
Courts actually have jurisdiction over the case but an court from reviewing or interfering with the judgment of a
administrative body/agency has the competence to resolve co-equal court over which it has no appellate jurisdiction
the case. As a result, the court must first allow the or power of review. This doctrine applies with equal force to
determination of the administrative agency. administrative bodies. When the law provides for an appeal
from the decision of an administrative body to the SC or CA,
TN: Noncompliance will lead to SUSPENSION of the case it means that such body is co-equal with the RTC and logically
beyond the control of the latter.
Corollary to the doctrine of primary jurisdiction is the principle
of exhaustion of administrative remedies. The Court, in a long
line of cases, has held that before a party is allowed to seek
the intervention of the courts, it is a pre-condition that he avail
himself of all administrative processes afforded him. Hence, if
a remedy within the administrative machinery can be resorted
to by giving the administrative officer every opportunity to
decide on a matter that comes within his jurisdiction, then
such remedy must be exhausted first before the courts power
of judicial review can be sought

Exceptions:
(a) where there is estoppel on the part of the party invoking
the doctrine;
(b) where the challenged administrative act is patently
illegal, amounting to lack of jurisdiction; (c) where there
is unreasonable delay or official inaction that will
irretrievably prejudice the complainant;
(c) where the amount involved is relatively so small as to
make the rule impractical and oppressive;
(d) where the question involved is purely legal and will
ultimately have to be decided by the courts of justice;
(e) where judicial intervention is urgent;
(f) where the application of the doctrine may cause great
and irreparable damage;
(g) where the controverted acts violate due process;
(h) where the issue of non-exhaustion of administrative
remedies has been rendered moot;
(i) where there is no other plain, speedy and adequate
remedy;
(j) where strong public interest is involved; and
(k) in quo warranto proceedings.

Doctrine of Judicial Hierarchy

This is an ordained sequence of recourse to courts vested

with concurrent jurisdiction, beginning from the lowest, on
to the next highest and ultimately to the highest. This
hierarchy is determinative of the venue of appeals, and is
likewise determinative of the proper forum for petitions for
extraordinary writs. This is an established policy necessary to
avoid inordinate demands upon the Court’s time and
attention which are better devoted to those matters within
its exclusive jurisdiction, and to preclude the further
clogging of the Court’s docket.

TN: Concurrent jurisdiction is a precondition; this operates

only when different courts have concurrent jurisdiction over
the case.

Exception:
Presence of exceptional and compelling reasons justified a
disregard of the rule which must be clearly and specifically set
out in the petition

Doctrine of Continuity of Jurisdiction / Adherence of

Jurisdiction

Once a court has acquired jurisdiction, that jurisdiction

continues until the court has done all that it can do in the
exercise of that jurisdiction. This principle also means that
once jurisdiction has attached, it cannot be ousted by
subsequent happenings or events and retains that jurisdiction
until it finally disposes of the case.

Even the finality of the judgment does not totally deprive the
court of jurisdiction over the case. What the court loses is the
power to amend, modify or alter the judgment. Even after the
judgment has become final, the court retains jurisdiction
to enforce and execute it.

Doctrine of Judicial Stability / Non-Interference

Courts of equal and coordinate jurisdiction cannot

interfere with each other’s orders. Thus, the RTC has no
power to nullify or enjoin the enforcement of a writ of