SITTIE FATIMA PANTAO

JD1-C

CASE TITLE : Leo Echegaray vs. Secretary of Justice (G.R. No. 132601)

Facts:

The Supreme Court dated January 4, 1990 issued a temporary restraining order to stay
the execution of petitioner Echegaray and Supplemental Motion to Urgent Motion for
Reconsideration.

In their Supplemental Motion to Urgent Motion for Reconsideration, public respondents

attached a copy of House Resolution No. 629 introduced by Congressman Golez entitled
"Resolution expressing the sense of the House of Representative to reject any move to
review Republic Act No. 7659 which provided for the re-imposition of death penalty,
notifying the Senate, the Judiciary and the Executive Department of the position of the
House of Representative on this matter, and urging the President to exhaust all means
under the law to immediately implement the death penalty law." The Resolution was
concurred in by one hundred thirteen (113) congressman.

In their Consolidated Comment, petitioner contends: (1) the stay order. . . is within the
scope of judicial power and duty and does not trench on executive powers nor on
congressional prerogatives; (2) the exercise by this Court of its power to stay execution
was reasonable; (3) the Court did not lose jurisdiction to address incidental matters
involved or arising from the petition; (4) public respondents are estopped from
challenging the Court's jurisdiction; and (5) there is no certainty that the law on capital
punishment will not be repealed or modified until Congress convenes and considers all
the various resolutions and bills filed before it.

Issue:

Whether or not the Court lost its jurisdiction upon a decided case with final judgment

Ruling:

The Court has not lost its jurisdiction over the case at bar, hence can still restrain the
execution of the petitioner.

The finality of a judgment does not mean that the Court has lost all its powers nor the
case. By the finality of the judgment, what the court loses is its jurisdiction to amend,
modify or alter the same. Even after the judgment has become final the court retains its
jurisdiction to execute and enforce it. There is a difference between the jurisdiction of the
court to execute its judgment and its jurisdiction to amend, modify or alter the same. The
former continues even after the judgment has become final for the purpose of
enforcement of judgment; the latter terminates when the judgment becomes final. For
after the judgment has become final facts and circumstances may transpire which can
render the execution unjust or impossible.

The power to control the execution of its decision is an essential aspect of jurisdiction. It
cannot be the subject of substantial subtraction for our Constitution vests the entirety of
judicial power in one Supreme Court and in such lower courts as may be established by
law. To be sure, the important part of a litigation, whether civil or criminal, is the process
of execution of decisions where supervening events may change the circumstance of the

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parties and compel courts to intervene and adjust the rights of the litigants to prevent
unfairness. It is because of these unforseen, supervening contingencies that courts have
been conceded the inherent and necessary power of control of its processes and orders
to make them conformable to law and justice. For this purpose, Section 6 of Rule 135
provides that "when by law jurisdiction is conferred on a court or judicial officer, all
auxiliary writs, processes and other means necessary to carry it into effect may be
employed by such court or officer and if the procedure to be followed in the exercise of
such jurisdiction is not specifically pointed out by law or by these rules, any suitable
process or mode of proceeding may be adopted which appears conformable to the spirit
of said law or rules." It bears repeating that what the Court restrained temporarily is the
execution of its own Decision to give it reasonable time to check its fairness in light of
supervening events in Congress as alleged by petitioner. The Court, contrary to popular
misimpression, did not restrain the effectivity of a law enacted by Congress.

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CASE TITLE: Malingin vs. Sandagan (G.R. No. 240056)

Facts:

Datu Malingin (Lemuel Talingting y Simborio), a tribal chieftain of the Higaonon-

Sugbuanon tribe, was accused of having carnal knowledge of a 14-year-old minor, AAA,
on six occasions by force, threat, intimidation, and by taking advantage of superior
strength. Consequently, Criminal Case Nos. 3821, 3822, 3823, 3824, 3825, and 3826
were filed against him for rape and raffled with the RTC presided by Judge Carlos O.
Arguelles.

Issue:

The main issue in this case was whether the Regional Trial Court (RTC) had jurisdiction
to settle disputes involving Indigenous Peoples (IP) and whether the prosecutor should
refrain from prosecuting cases involving IPs.

Ruling:

The court dismissed the petition, stating that the petitioner failed to observe the doctrine
of hierarchy of courts and that the invocation of the provisions of Republic Act No. 8371
(the Indigenous Peoples Rights Act) was insufficient to evade criminal prosecution.

Ratio:

The court emphasized the doctrine of hierarchy of courts, which guides litigants on the
proper forum for their appeals and the venue for the issuance of extraordinary writs. The
court stated that direct recourse to the Supreme Court is allowed only in exceptional or
compelling instances, and failure to observe the doctrine warrants the dismissal of the
case. The court also clarified that the provisions of Republic Act No. 8371 do not serve as
a bar for criminal prosecution, as penal laws apply to individuals without regard to their
membership in an indigenous cultural community.

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CASE TITLE: BSP vs Banco Filipino G.R. No. 196580

Facts:

Banco Filipino Savings and Mortgage Bank (Banco Filipino) filed three separate civil
actions against the Bangko Sentral ng Pilipinas and its Monetary Board (BSP-MB)
challenging the validity of resolutions and seeking damages. The cases were:

1. Civil Case No. 8108: Filed on August 6, 1984, seeking to annul Resolution No. 955 of
the Monetary Board of the then Central Bank of the Philippines (Central Bank), which
placed Banco Filipino under conservatorship.
2. Civil Case No. 9675: Filed on February 2, 1985, seeking to annul and set aside
Resolution No. 75 of the Monetary Board of the then Central Bank, which ordered the
closure of Banco Filipino.
3. Civil Case No. 10183: Filed on June 3, 1985, challenging the validity of the resolution
dated March 22, 1985 of the Monetary Board of the then Central Bank, which ordered the
liquidation of Banco Filipino.

Issue: The issue was whether the BSP-MB’s resolutions were valid.

Ruling: The court’s ruling is not explicitly mentioned in the search results.

Ratio: The Doctrine of Non-Interference, also known as the Doctrine of Judicial Stability,
is an elementary principle in the administration of justice. It states that no court can
interfere by injunction with the judgments or orders of another court of concurrent
jurisdiction having the power to grant the relief sought by the injunction. This doctrine
applies with equal force to administrative bodies. In the context of this case, the doctrine
would imply that no other court or administrative body of concurrent jurisdiction could
interfere with the judgments or orders issued by the BSP-MB regarding Banco Filipino.

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CASE TITLE: Baritua vs Mercader 350 SCRA 86

Facts:

Dominador Mercader boarded the bus of herein petitioner JB Line bounded from Manila
to N. Samar as a paying passenger on March 16, 1983. However, while said bus was
traversing the Beily Bridge in N. Samar, the bus fell into the river and as a result,
Mercader died.
The accident happened because [petitioners’] driver negligently and recklessly operated
the bus at a fast speed in wanton disregard of traffic rules and regulations and the
prevailing conditions then existing that caused the bus to fall into the river. The heirs of
Mercader then filed a motion to declare the petitioners in default, in which the petitioners
opposed.
After due trial the RTC (Branch 21, Laoang, Northern Samar) rendered its decision in
favor of the respondents and against the petitioner. The court of appeals sustained the
decision of the RTC and affirmed all the monetary damages being granted upon except
for the modification of the loss of earning.
With the heirs of Mercader attaining a favorable judgment at the lower court and CA level,
petitioner assails the said decisions rendered therein with the Supreme Court via Petition
for Review under Rule 45 on the ground of procedural flaws, specifically questioning: (1)
the jurisdiction of the lower court over the original and amended complaints or over the
subject matter of the case as the trial court was not paid the correct amount of docket and
other lawful fees; (2) the arbitrary disregard for petitioner’s constitutional right to
procedural due process and fairness as the appellate court denied their right to present
evidence, to expect that their evidence will be duly considered and appreciated and when
the court passed sub silencio on the trail court’s failure to rule frontally on petitioner’s plea
for a bill of particulars; and (3) that both the RTC and CA failed to adhere to the rule that
their decision must state clearly and distinctly the facts and the laws on which they are
based.

Issues:
I. Whether or not the RTC had jurisdiction over the subject matter of the case

Held:
I. No. The Supreme Court held that the trial court did not acquire jurisdiction over
the subject matter of the case on the ground that the respondents did not pay the docket
and other lawful fees as contended by the petitioners.

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 The Court, in Manchester Development Corporation v. CA, held that “the court
acquires jurisdiction over any case only upon the payment of the prescribed
docket fee An amendment of the complaint or similar pleading will not thereby vest
jurisdiction in the court, much less the payment of the docket fee based on the
amounts sought in the amended pleading.”
First, judges cannot be expected to rely on the testimonies of every witness. In
ascertaining the facts, they determine who are credible and who are not. In doing so,
they consider all the evidence before them. In other words, the mere fact that Judge
Noynay based his decision on the testimonies of respondents’ witnesses does not
necessarily mean that he did not consider those of petitioners.
Second, there is no sufficient showing that Judge Operario was overzealous in
questioning the witnesses. His questions merely sought to clarify their testimonies.
Hence, the SC rejects the petitioner’s contention that their right to adduce
evidence was violated.

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CASE TITLE: Felixberto Cubero et al. vs. Laguna West Multi-Purpose
Cooperative, Inc. GR No. 166833

Facts:
The present petition raises the issue of jurisdiction over the subject matter. Individual
petitioners Felixberto Cubero, Nerrisa C. Natividad, Judy U. Lim, Manuel R. Lahoz and
Sotero Diola are the registered owners of various parcels of land covered by twelve (12)
Transfer Certificates of Title (TCTs). The properties cover a total land area of about
78,178 square meters located in Barangay Suplang, Tanauan, Batangas.
In August 2003, each of the individual petitioners entered into a Joint Venture
Development Agreement with co-petitioner Belle Corporation to develop the properties as
part of an agricultural farm lot subdivision project known as "Plantation Hills at Tagaytay
Greenlands Phase I" (the Project) for eventual sale to the public.
With the development of the Project in full swing in mid-2004, respondent Laguna West
Multi-Purpose Cooperative, Inc. (Laguna West Cooperative) filed 9 ex-parte petitions with
the Regional Trial Court (RTC) of Tanauan City, for inscription of an adverse claim, the
annotation of which the Registrar of Deeds allegedly failed to carry over to the TCTs of
individual petitioners under the Property Registration Decree. Laguna West Cooperative
added that the petitions were filed to rectify the omission or error and to protect its vested,
subsisting and valid rights under the JVAs.
Getting wind of the petitions filed by Laguna West Cooperative, petitioners also filed a
Complaint10 with the RTC of Tanauan, for "Annulment of Joint Venture Agreements with
prayer for the issuance of a TRO and/or writs of Preliminary Injunction and Preliminary
Mandatory Injunction and for Damages" against herein respondents Laguna West
Cooperative and Atty. Abraham Bermudez in the latter's capacity as Registrar of Deeds
of Tanauan.
In their Complaint, petitioners asserted that the April 1996 JVAs between Laguna West
Cooperative and individual petitioners' predecessors-in-interest are void ab initio since
they were executed within the 10- year prohibitory period under Republic Act No. 6657
(Comprehensive Agrarian Reform Law of 1988),12 the titles covering the properties
having emanated from emancipation patents granted in November 1988 pursuant to
Presidential Decree No. 27.

ISSUE:
Whether or not N the RTC of Batangas obtained jurisdiction as opposed to claim by
Cuberos that DARAB has primary jurisdiction

RULING:
YES, the RTC of Batangas has jurisdiction over the subject matter. It is axiomatic that
what determines the nature of an action, as well as which court has jurisdiction over it,
are the allegations in the complaint and the character of the relief sought. In the
determination of jurisdiction, the status or relationship of the parties, as well as the nature
of the question that is the subject of their controversy, is also considered.
The Department of Agrarian Reform (DAR) is vested with primary jurisdiction to
determine and adjudicate agrarian reform matters, with exclusive original jurisdiction over
all matters involving the implementation of agrarian reform except those falling under the
exclusive jurisdiction of the Department of Agriculture and the Department of
Environment and Natural Resources. Original jurisdiction means jurisdiction to take
cognizance of a cause at its inception, try it and pass judgment upon the law and facts,
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while exclusive jurisdiction precludes the idea of co-existence and refers to jurisdiction
possessed to the exclusion of others.
There is no question that the instant case does not involve agrarian dispute and that the
parties have no tenurial relationship. The Court dismissed the complaint not because the
subject of the questioned JVAs is an agricultural land as erroneously assumed by the
plaintiffs. The complaint was dismissed because it involves controversy or issue in the
implementation of R.A. 6657 – that is – whether or not the agricultural land beneficiaries
has reneged its (sic) obligation by entering in the joint venture agreements and whether
the terms thereof are violative of Sections 27 and 73 of the said Act including the
restrictions annotated on the emancipation patents certificates.
The JVAs subject of the petition for annulment of petitioners precisely involve the
development and utilization of the subject agricultural lands. As successors-in-interest of
the beneficiaries of the agricultural lands, individual petitioners seek to nullify the JVAs.
Since the controversy involves the rights and obligations of persons engaged in the
management, cultivation and use of an agricultural land covered by CARP, the case falls
squarely within the jurisdictional ambit of the DAR.

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CASE TITLE: Land Bank of the Philippines vs. Eugenio Dalauta, G.R. No. 190004

Facts:

Eugenio Dalauta was the registered owner of an agricultural land in Florida, Butuan City.
The land was placed by the Department of Agrarian Reform (DAR) under compulsory
acquisition of the Comprehensive Agrarian Reform Program (CARP). Dalauta received a
Notice of Coverage notifying him that his land was subject of expropriation. Land Bank of

the Philippines (LBP) offered ₱192,782.59 as compensation for the land, but Dalauta
rejected such valuation for being too low. The case was referred to the DAR Adjudication
Board (DARAB). A summary administrative proceeding was conducted to determine the
appropriate just compensation for the subject property.

Issue: Whether or not the valuation of Dalauta’s land should be determined using the
formula in DAR A.O. No. 6, series of 1992.

Ruling:

The Regional Trial Court, sitting as Special Agrarian Court (SAC), rendered its decision
pegging the just compensation in the amount of ₱2,639,557.00, higher than the value
made by LBP. LBP filed a motion for reconsideration, but it was denied by the SAC.

Ratio:

Appellate jurisdiction refers to the power of a court to hear appeals from lower courts. In
this case, LBP filed a petition for review under Rule 42 of the Rules of Court before the
Court of Appeals, arguing that the SAC erred in taking cognizance of the case when the
DARAB decision sustaining the LBP valuation had long attained finality. This is an
example of the exercise of appellate jurisdiction, where a higher court (the Court of
Appeals) has the power to review and modify the decision of a lower court (the SAC).

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CASE TITLE: G.R. No. 194751 - De Pedro vs. Romasan Development
Corporation
Facts:

The case originated from separate complaints for nullification of free patent and original
certificates of title, filed against several defendants, including petitioner Aurora De Pedro.
The complaints were filed by respondent Romasan Development Corporation before the
Regional Trial Court of Antipolo City on July 7, 1998. Romasan Development Corporation
alleged that it was the owner and possessor of a parcel of land in Antipolo City, covered
by Transfer Certificate of Title (TCT) No. 236044. De Pedro put up fences on a portion of
Romasan’s Antipolo property.

Issue:

Whether or not the court acquired jurisdiction over the person of the defendant,
considering the mode of service of summons.

Ruling:

The Supreme Court ruled that regardless of the type of action - whether it is in personam,
in rem, or quasi in rem - the preferred mode of service of summons is personal service.
To avail themselves of substituted service, courts must rely on a detailed enumeration of
the sheriff’s actions and a showing that the defendant cannot be served despite diligent
and reasonable efforts. The sheriff’s return, which contains these details, is entitled to a
presumption of regularity, and on this basis, the court may allow substituted service.
Should the sheriff’s return be wanting of these details, substituted service will be irregular
if no other evidence of the efforts to serve summons was presented. Failure to serve
summons will mean that the court failed to acquire jurisdiction over the person of the
defendant. However, the filing of a motion for new trial or reconsideration is tantamount to
voluntary appearance.

Ratio:

Jurisdiction over the subject matter is the court’s power to hear and determine cases of
the general class to which the proceedings in question belong and to deal with the
general subject involved in the action before the court and to grant the relief demanded.
In this case, the court’s jurisdiction over the subject matter was not in question. The issue
was whether the court acquired jurisdiction over the person of the defendant, which is a
separate aspect of jurisdiction.

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CASE TITLE: REPUBLIC OF THE PHILIPPINES vs. PILAR ESTIPULAR G.R. No.
136588

Facts:
Pilar Estipular, the only surviving legal heir of the late Fermin Estipular, filed a Petition for
Reconstitution of Title before the Regional Trial Court of La Union. Fermin Estipular was
issued Certificate of Title No. 154 by the Register of Deeds of La Union covering a parcel
of land located at Barrio Liquicia, Caba, La Union, with an area of 6.1253 hectares. The
said Certificate of Title was either destroyed or burned as a result of the burning of the
Register of Deeds of La Union during the last World War.

Issue:
Whether or not there is compliance with the requirements provided by law to clothe the
Court with jurisdiction.

Ruling:
The Supreme Court ruled that the trial court did not acquire jurisdiction over the case.
One of the requirements laid down by RA 26 is that the Notice of Petition must be posted
on the main entrance of the provincial building and of the municipal building of the
municipality or city in which the land is situated, at least thirty days prior to the date of
hearing.
In this case, it is undisputed that the Notice of Hearing of respondent’s Petition for
Reconstitution was not posted at the main entrance of the provincial building.

Ratio:
Jurisdiction over the subject matter or nature of the action is conferred only by the
Constitution or by law. It cannot be granted by the agreement of the parties, acquired,
waived, enlarged or diminished by any act or omission of the parties, or conferred by the
acquiescence of the courts. In other words, the court’s acquisition of jurisdiction hinged
on a strict compliance with the requirements of the law. The requirements laid down by
Republic Act No 26 are mandatory and compliance with them is jurisdictional.
Hence, the principle of substantial compliance cannot be applied to the present case, as
the trial court’s acquisition of jurisdiction over the Petition hinged on a strict compliance
with the requirements of the law.

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CASE TITLE: G.R. No. 231290, Velasquez Jr. vs Lisondra Land Inc.

Facts:
In 1998, petitioner Perfecto Velasquez, Jr. and respondent company Lisondra Land
Incorporated entered into a joint venture agreement to develop a 7,200-square meter
parcel of land into a memorial park.
However, due to numerous issues surrounding the project, including Lisondra Land’s
failing to acquire an HLURB on time, failing to provide insurance coverage and to pay its
share in the realty taxes, and receiving kickbacks from contractors and agents, Perfecto
filed a complaint for breach of contract before the Regional Trial Court (RTC).

Issue:
Whether or not the RTC had jurisdiction over the case, as Lisondra Land claimed that the
violations involved real estate trade and business practices which are within the HLURB’s
exclusive authority.

Ruling:
Yes. The RTC ruled that it is competent to decide the case. However, the CA granted
Lisondra Land’s petition and ordered to dismiss Civil Case No. 18146, holding that the
RTC committed grave abuse of discretion in taking cognizance of the complaint. The CA
explained that Lisondra Land’s alleged acts constitute unsound real estate business
practices falling under the HLURB’s jurisdiction.

Ratio:
In his current petition before the SC, Perfecto argued that Lisandro Land is now estopped
from assailing the HLURB’s jurisdiction. This means that Lisondra Land, having initially
claimed that the HLURB had jurisdiction, cannot later deny this jurisdiction when the
decision is not in their favor. This is an application of the legal principle of estoppel, which
prevents a party from asserting a claim or right that contradicts what they previously
claimed or agreed to.

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CASE TITLE: Biaco vs. Philippine Countryside Rural Bank (515 SCRA 106)

Facts:
Ernesto Biaco, husband of Teresa Biaco, obtained several loans from the Philippine
Countryside Rural Bank (PCRB) from 1996 to 1998. To secure the loans, he mortgaged
certain property in favor of the bank. He was able to pay loans from 1996 to 1997 but
defaulted in loans obtained in 1998 which amounted to more than a million pesos. PCRB
filed a complaint for foreclosure against the spouses Biaco. Summons were issued by the
trial judge and served to Ernesto at his office. No summons was served to Teresa. The
spouses were declared in default upon motion of the respondent bank.

Issue:
Whether or not the judgment of the trial court should be annulled due to the violation of
Teresa’s right to due process when she did not receive summons.

Ruling:
Yes. The court ruled that Teresa’s constitutional right to due process was violated when
she did not receive summons. As a resident defendant, who does not voluntarily appear
in court, she must be personally served with summons as provided under Section 6, Rule
14 of the Rules of Court. Even if the action is quasi in rem, personal service of summons
is essential in order to afford her due process.

Ratio:
The court’s jurisdiction over the parties in a quasi in rem proceeding is not required as
long as the court acquires jurisdiction over the res (the property in question). However,
the constitutional right to due process is superior over these procedural matters.
Therefore, even in a quasi in rem proceeding, personal service of summons is essential
to afford due process.

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CASE TITLE: 73 Phil 484 Reyes vs Diaz

FACTS:
Both parties agree that if the due filing of the protestant's certificate of candidacy is
proven. The trial court has jurisdiction, but that if such fact is not proven the trial court has
no jurisdiction except to dismiss the case. There is, therefore, no question between the
parties as to what the jurisdiction of the trial court is according to law in either case. The
real question between them is one of fact whether or not the protestant's certificate of
candidacy has been duly filed. And not until this fact is proved can the question of
jurisdiction be determined. Neither is the second question one of jurisdiction within the
purview of the legal provisions above quoted. Whether certain ballots are or are not
pertinent to the issue raised in the pleadings, is merely a question of relevancy of
evidence. It may be true that the court by an erroneous ruling on such question may
encroach upon issues completely foreign to those defined in the pleadings, but in such
case the question of jurisdiction that may arise would not be one of jurisdiction over the
subject-matter but of jurisdiction over the issue. In order that a court may validly try and
decide a case, it must have jurisdiction over the subject-matter and jurisdiction over the
persons of the parties. But in some instances it is said that the court should also have
jurisdiction over the issue, meaning thereby that the issue being tried and decided by the
court be within the issues raised in the pleadings.

ISSUE:
Whether or not the question of jurisdiction that may arise would be one of jurisdiction over
the subject matter or jurisdiction over the issue.

HELD:
There is no such question of jurisdiction over the subject matter.

In order that a court may validly try and decide a case, it must have jurisdiction over the
persons of the parties. But in some instances, it is said that the court should also have
jurisdiction over the issue, meaning thereby that the issue being tried and decided by the
court be within the issues raised in the pleadings. But this kind of jurisdiction should be
distinguished from jurisdiction over the subject-matter the latter being conferred by law
and the former by the pleadings. Jurisdiction over the issue, unlike jurisdiction over the
subject-matter, may be conferred by consent either express or implied of the parties.
(Rule 17, sec. 4, Rules of Court.)

Although an issue is not duly pleaded it may validly be tried and decided if no timely
objection is made thereto by the parties. This cannot be done when jurisdiction over the
subject-matter is involved. In truth, jurisdiction over the issue is an expression of a
principle that is involved in jurisdiction over the persons of the parties. Where, for
instance, an issue is not duly pleaded in the complaint, the defendant cannot be said to
have been served with process as to that issue. (Cf. Atkins etc. Co. vs. Domingo, 44 Phil.
680). At any rate, whether or not the court has jurisdiction over a specific issue is a
question that requires nothing except an examination of the pleadings, and this function is
without such importance as call for the intervention of this Court.
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Furthermore, this question of jurisdiction is unsubstantial. It is well-settled rule that the
institution of suffrage is of public, not private, interest, and the court may examine all the
ballots after the ballot boxes are opened in order to determine which are legal and which
are illegal, even though neither of the parties raised any question as to their illegality.

This case was remanded to the Court of Appeals for further proceedings.

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CASE TITLE: G.R. No. 208232 Heirs of Bautista vs Lindo

Facts:
Alfredo R. Bautista (Bautista), the predecessor of the petitioners, inherited a free-patent
land located in Poblacion, Lupon, Davao Oriental in 1983, which was covered by Original
Certificate of Title (OCT) No. (1572) P-61441. A few years later, he subdivided the
property and sold it to several vendees, the respondents, via a notarized deed of absolute
sale dated May 30, 19911. Two months later, OCT No. (1572) P-6144 was canceled and
Transfer Certificates of Title (TCTs) were issued in favor of the vendees. Three years
after the sale, or on August 5, 1994, Bautista filed a complaint for repurchase against
respondents before the RTC, Branch 32, Lupon, Davao Oriental, docketed as Civil Case
No. 17981.

Issue:
Whether or not the action for repurchase is a civil action incapable of pecuniary
estimation.

Ruling:
Yes. The Supreme Court reversed the trial court’s dismissal of the complaint for lack of
jurisdiction. The court ruled that an action to redeem a land subject to a free patent is a
civil action incapable of pecuniary estimation. It falls under the category of specific
performance, which is considered incapable of pecuniary estimation and is cognizable
exclusively by the RTC.

Ratio:
The case revolves around the right of repurchase of a free-patent land. The court ruled
that an action to redeem a land subject to a free patent is a civil action incapable of
pecuniary estimation. It falls under the category of specific performance, which is
considered incapable of pecuniary estimation and is cognizable exclusively by the RTC.
This means that the value of the action cannot be estimated in terms of money, but
rather, it involves the enforcement of a party’s rights and obligations.

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CASE TITLE: G.R. No. 184203, City of Lapu-Lapu vs. Philippine Economic Zone
Authority (PEZA)

Facts:
In 1972, President Ferdinand E. Marcos issued Presidential Decree No. 66, establishing
export processing zones in strategic locations in the Philippines and creating the Export
Processing Zone Authority (EPZA) to manage these zones. The EPZA was declared non-
profit and exempt from all taxes. In 1995, the Special Economic Zone Act of 1995 (RA
7916) was enacted, creating the PEZA, which assumed all of EPZA’s powers. The City of
Lapu-Lapu demanded about P32M from the PEZA for the payment of real property taxes
incurred from 1992 to 1998, for properties located in the Mactan Economic Zone. The
City cited Sections 193 and 234 of the Local Government Code 1991 that withdrew the
real property tax exemptions previously granted to all persons.

Issue:
Whether or not the Philippine Economic Zone Authority (PEZA) is exempt from payment
of real property taxes.

Ruling:
Yes. The Regional Trial Court ruled that the PEZA is exempt from payment of real
property taxes. The court stated that Sections 193 and 234 of the Local Government
Code had withdrawn the real property tax exemptions previously granted to all persons,
whether natural or juridical. As to the tax exemptions under Section 51 of the Special
Economic Zone Act of 1995, the trial court ruled that the provision only applies to
businesses operating within the economic zones, not to the PEZA. The City of Lapu-Lapu
appealed to the Court of Appeals, which dismissed the appeal, ruling that the City availed
of the wrong mode of appeal.

Ratio:
The issue of jurisdiction was raised in this case. Specifically, the question was "Whether
the Regional Trial Court of Pasay City had jurisdiction to hear, try, and decide the City of
Lapu-Lapu’s petition for declaratory relief?". The court ruled that the law sought to be
judicially interpreted in this case had already been breached. Therefore, the Regional
Trial Court of Pasay did not have jurisdiction over the PEZA’s petition for declaratory
relief against the City.

.
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CASE TITLE: G.R. No. 182970, Samson vs. Spouses Gabor

Facts:
Respondent spouses Jose and Guillermina Gabor are the registered owners of a parcel
of land with an area of Sixty-One Thousand Eighty-Five (61,085) square meters, situated
at Barrio Mapunso, Tanay, Rizal Province. On November 14, 1985, the Spouses Gabor
executed a Deed of Assignment transferring Twenty Thousand Six Hundred Thirty-One
(20,631) square meters undivided portion of the aforementioned parcel of land in favor of
petitioner Emiliano S. Samson as attorney’s fees in payment for the services rendered by
the latter for the former. Upon learning of the sale, respondent spouses filed an action for
legal redemption with the RTC of Tanay, Rizal.
Issue:
Whether or not the respondent spouses have the right of legal redemption over the
20,631 square meters involved.

Ruling:
The RTC dismissed the suit for legal redemption. However, on appeal, the CA reversed
the decision of the RTC and upheld the Spouses Gabor’s right of legal redemption. The
CA upheld the lower court’s decision, stating that in view of the final and executory
decision in CA-G.R. No. 25530 upholding the right of defendants-appellees to exercise
their right of legal redemption over the 20,631 square meters involved, plaintiff-appellant
is devoid of any legal right or personality to ask for partition of [the] subject property
formerly owned in common.

Ratio:
This case is related to the civil procedure’s jurisdiction as it involves the exercise of the
right of legal redemption, which is a civil matter. The case was initially heard by the RTC,
a lower court with general jurisdiction over civil cases. However, the decision of the RTC
was appealed to the CA, a higher court with appellate jurisdiction over decisions rendered
by lower courts. The final decision of the CA was upheld, demonstrating the hierarchical
jurisdiction of courts in the Philippine judicial system.

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CASE TITLE: Universal Robina Corp vs. Lim 535 SCRA 95, 99

Facts:
The case involves a contract of sale between Universal Robina Corporation (petitioner)
and Albert Lim (respondent). Pursuant to the contract, petitioner sold grocery products to
respondent amounting to P 808,059.881. After tendering partial payments, respondent
refused to settle his obligation despite petitioner’s repeated demands. Thus, petitioner
filed a complaint for a sum of money with the Regional Trial Court, Branch 227, Quezon
City.

Issue:
Whether or not the trial court was correct in dismissing the complaint on the grounds of
lack of jurisdiction and improper venue.

Ruling:
The trial court initially dismissed the complaint for lack of jurisdiction and improper venue.
However, upon petitioner’s motion for reconsideration, the trial court admitted the
amended complaint. Subsequently, the trial court dismissed the complaint again on the
ground of improper venue. Petitioner filed a petition for review with the Court of Appeals,
but it was dismissed due to procedural non-compliance. The Court of Appeals denied
petitioner’s motion for reconsideration.

Ratio:
This case highlights the importance of proper venue and jurisdiction in civil procedure.
The trial court initially dismissed the case due to lack of jurisdiction and improper venue,
indicating that the court did not have the authority to hear the case, and the case was not
filed in the correct geographical location. This demonstrates the critical role of jurisdiction
and venue in ensuring that legal disputes are resolved in an appropriate and lawful
manner. It also underscores the necessity for parties to adhere to rules of procedure to
ensure the fair and efficient administration of justice.

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CASE TITLE: GR No. 204444, Briones vs CA

Facts:
The case involves a complaint filed by Virgilio C. Briones against Cash Asia Credit
Corporation (Cash Asia) for nullity of mortgage contract, promissory note, loan
agreement, foreclosure of mortgage, cancellation of transfer certificate of title (TCT)
No.290846, and damages. Briones alleged that he is the owner of a property and that his
property had been foreclosed and a writ of possession had already been issued in favor
of Cash Asia. He claimed that he never contracted any loans from Cash Asia as he has
been living and working in Vietnam since October 31, 2007. Briones assailed the validity
of the contracts claiming his signature to be forged.

Issue:
Whether or not the CA gravely abused its discretion in ordering the outright dismissal of
Briones’s complaint on the ground of improper venue.

Ruling:
The RTC denied Cash Asia’s motion to dismiss for lack of merit. The CA, however,
annulled the RTC Orders, and dismissed Briones’s complaint without prejudice to the
filing of the same before the proper court in Makati. The Supreme Court ruled that the CA
patently erred and hence committed grave abuse of discretion in dismissing Briones’s
complaint on the ground of improper venue.

Ratio:
This case highlights the principle that while the venue of personal actions is the court
which has jurisdiction where the plaintiff or the defendant resides, at the election of the
plaintiff, a complaint directly assailing the validity of the written instrument itself should not
be bound by the exclusive venue stipulation contained therein and should be filed in
accordance with the general rules on venue. Given this circumstance, Briones cannot be
expected to comply with the aforesaid venue stipulation, as his compliance therewith
would mean an implicit recognition of their validity.

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