General v. Special or Limited Jurisdiction (Gonzales v. GJH Land)
General v. Special or Limited Jurisdiction (Gonzales v. GJH Land)
The Court's designation of Special Commercial Courts (on June In all the above-mentioned scenarios, any difference regarding
17, 2003, the Court issued A.M. No. 03-03-03-SC consolidating the applicable docket fees should be duly accounted for. On the
the commercial SEC courts and the intellectual property courts in other hand, all docket fees already paid shall be duly credited,
one RTC branch in a particular locality, i.e., the Special and any excess, refunded.
Commercial Court, to streamline the court structure and to
promote expediency) was made in line with its constitutional The transfer of the present intra-corporate dispute from Branch
authority to supervise the administration of all courts as provided 276 to Branch 256 of the same RTC of Muntinlupa City, subject to
under Section 6, Article VIII of the 1987 Constitution: the parameters above-discussed is proper and will further the
purposes stated in A.M. No. 03-03-03-SC of attaining a speedy
Section 6. The Supreme Court shall have administrative and efficient administration of justice.
supervision over all courts and the personnel thereof.
The same principles apply to the inverse situation of ordinary civil
The objective behind the designation of such specialized courts is cases filed before the proper RTCs but wrongly raffled to its
to promote expediency and efficiency in the exercise of the RTCs' branches designated as Special Commercial Courts. In such a
jurisdiction over the cases enumerated under Section 5 of PD scenario, the ordinary civil case should then be referred to the
902-A. Such designation has nothing to do with the statutory Executive Judge for re-docketing as an ordinary civil case;
conferment of jurisdiction to all RTCs under RA 8799 since in the thereafter, the Executive Judge should then order the raffling of
first place, the Court cannot enlarge, diminish, or dictate when the case to all branches of the same RTC, subject to limitations
jurisdiction shall be removed, given that the power to define, under existing internal rules, and the payment of the correct
prescribe, and apportion jurisdiction is, as a general rule, a matter docket fees in case of any difference. Unlike the limited
of legislative prerogative. assignment/raffling of a commercial case only to branches
designated as Special Commercial Courts in the scenarios stated
Case at bar: Here, petitioners filed a commercial case, i.e., an above, the re-raffling of an ordinary civil case in this instance to all
intra-corporate dispute, with the Office of the Clerk of Court in the courts is permissible due to the fact that a particular branch
RTC of Muntinlupa City, which is the official station of the which has been designated as a Special Commercial Court does
designated Special Commercial Court, in accordance with A.M. not shed the RTC's general jurisdiction over ordinary civil cases
No. 03-03-03-SC. It is, therefore, from the time of such filing that under the imprimatur of statutory law, i.e., Batas Pambansa
the RTC of Muntinlupa City acquired jurisdiction over the subject Bilang (BP) 129.
matter or the nature of the action. Unfortunately, the commercial
case was wrongly raffled to a regular branch, e.g., Branch 276,
instead of being assigned to the sole Special Commercial Court