I.

Definitions and Concepts

A. Overview

1. Jurisdiction distinguished from exercise of jurisdiction

Antonino v. Register of Deeds, G.R. No. 185663, June 2012

FACTS:

Since March 21, 1978, petitioner RemediosAntonino had been leasing a residential property located at
Makati City and owned by private respondent Tan Tian Su (Su). Under the governing lease contract,
Antonino was accorded with the right of Frst refusal in the event Su would decide to sell the subject
property. On July 7, 2004, the parties executed a document denominated as Undertaking Agreement [4]
where Su agreed to sell to Antonino the subject property forP 39,500,000.00. However, in view of a
disagreement as to who between them would shoulder the payment of the capital gains tax, the sale did
not proceed as intended. On July 9, 2004, AntoninoFled a complaint against Su with the Regional Trial
Court (RTC) of Makati City, for the reimbursement of the cost of repairs on the subject property and
payment of damages. The complaint was ra±ed to Branch 149 and docketed as Civil Case No. 04-802.
Later that same day, AntoninoFled an amended complaint to enforce the Undertaking Agreement and
compel Su to sell to her the subject property. In an Order dated December 8, 2004, the RTC dismissed
Antonino’s complaint on the grounds of improper venue and non-payment of the appropriate docket
fees. According to the RTC, Antonino’s complaint is one for speciFc performance, damages and sum of
money, which are personal actions that should have been Fled in the court of the place where any of the
parties resides. Antonino and Su reside in Muntinlupa and Manila, respectively, thus Makati City is not
the proper venue.

ISSUE:

WON the lack of jurisdiction over the case is a ground for annulment? (YES)

RULING

A petition for annulment of judgment can only be based on “extrinsic fraud” and “lack of jurisdiction”
and cannot prosper on the basis of “grave abuse of discretion.” By anchoring her petition on the alleged
grave abuse of discretion that attended the dismissal of her complaint and the denial of her two (2)
motions for reconsideration, Antonino, is, in effect, enlarging the concept of “lack of jurisdiction.” As this
Court previously clarified in Republic of the Philippines v. “G” Holdings, Inc., 475 SCRA 608 (2005), “lack
of jurisdiction” as a ground for the annulment of judgments pertains to lack of jurisdiction over the
person of the defending party or over the subject matter of the claim. It does not contemplate “grave
abuse of discretion” considering that “jurisdiction” is different from the exercise thereof.

2. Error of Jurisdiction vis-a-vis error of judgment, Question of law vis-a-vis question of fact
Dipad v. Olivan, G.R. No. 168771, July 25, 2012

FACTS

Due to a collision between the car of petitioner spouses Dipad and the passenger jeep owned by
respondents, the former filed a civil action for damages before the sala of Municipal Trial Court (MTC)
Judge Clavecilla

During trial, Roberto Dipad mentioned in his direct testimony that because he was not able to make use
of his vehicle for his buy-and-sell business, he suffered damages by way of lost income for three months
amounting to P40,00

Then, during... cross-examination, the defense required him to produce his personal copy of his ITRs for
the years 2001, 2002 and 2003.[3]

Dipad vehemently objected on the ground of confidentiality of the ITRs. He also claimed that the
demand therefor was incriminatory and in the nature of a fishing expedition.

By reason of the opposition, Judge Clavecilla suspended the trial and required petitioners to show their
basis for invoking the confidentiality of the ITRs.

Aggrieved, the spouses Dipad filed a Motion for Reconsideration, which was denied by Judge Clavecilla.
Thereafter, they instituted a Rule 65 Petition for Certiorari and Prohibition before the RTC, assailing the
3 February 2005 Order of the MTC for having been issued with grave... abuse of discretion amounting to
lack or excess of jurisdiction. In that Petition, they opposed Judge Clavecilla's ruling in this wise:[4]

ISSUE

Petitioners insist that that the RTC committed reversible error in dismissing their Rule 65 Petition as an
improper appeal, since grave abuse of discretion amounting to excess of jurisdiction was committed by
MTC Judge

RULING

“Errors of Jurisdiction,” and “Errors of Judgment,” Distinguished.―As defined in jurisprudence, errors of

FACTS:

Respondent Eleto B. Banas worked at petitioner Century Iron until his dismissal. Banas responded to his
dismissal by filing a complaint for illegal dismissal with prayer for reinstatement and money claims.

Labor Arbiter ruled that Bañas was illegally dismissed.

The CA affirmed with modification the NLRC decision.

Petitioners now come before the Supreme Court.

ISSUE:

WON the CA erred in holding that the factual findings of the NLRC may not be inquired into considering
that only questions of law may be brought in an original action for certiorari

RULING:

A petition for review on certiorari under Rule 45 is an appeal from a ruling of a lower tribunal on pure
questions of law. It is only in exceptional circumstances that we admit and review questions of fact. A
question of law arises when there is doubt as to what the law is on a certain state of facts, while there is
a question of fact when the doubt arises as to the truth or falsity of the alleged facts. For a question to
be one of law, the question must not involve an examination of the probative value of the evidence
presented by the litigants or any of them. The resolution of the issue must rest solely on what the law
provides on the given set of circumstances. Once it is clear that the issue invites a review of the evidence
presented, the question posed is one of fact. Thus, the test of whether a question is one of law or of fact
is not the appellation given to such question by the party raising the same; rather, it is whether the
appellate court can determine the issue raised without reviewing or evaluating the evidence, in which
case, it is a question of law; otherwise it is a question of fact. On the other hand, a petition for certiorari
under Rule 65 is a special civil action, an original petition confined solely to questions of jurisdiction
because a tribunal, board or officer exercising judicial or quasi-judicial functions has acted without
jurisdiction or in excess of jurisdiction or with grave abuse of discretion amounting to lack of jurisdiction.

3. Jurisdiction conferred by law not by the parties nor by their agreement or consent

Heirs of Santiago Nisperos v. Nisperos-Dacusin, G.R. No. 189570, July 31, 2013

FACTS:

A petition for review of the Decisionand Resolution of the Court of Appeals (CA) which affirmed the
Decision of the Department of Agrarian Reform Adjudication Board (DARAB) upholding the validity of
the Deed of Voluntary Land Transfer (VLT) and Original Certificate of Title (OCT) No. CLOA-623 issued in
favor of the respondent.
The case stemmed from the complaint filed by petitioners with DARAB alleging that the subject portion
of the total of 5 hectares of agricultural land, acquired by their decedent during lifetime, was
subsequently transferred through the above VLT to the respondent without the consent of the former.
It is also alleged that the respondent, who stood only as the “ward” of one of the co-owners of the land
and did not allege in their complaint that a tenancy relationship exists, is not a bona fide beneficiary of
the subject land for being a minor and incapable of farming then when the VLT was executed.

The respondent alleged that the land was acquired by the co-owners from Santiago and possessed the
same openly, continuously, exclusively and publicly; thus, the consent of petitioners is not necessary to
the VLT. Moreover, the former insisted to be a bona fide beneficiary of the land that has been tilling
with the parents.

ISSUE

WHETHER OR NOT DARAB HAS JURISDICTION TO THE CASE.

RULING

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 DARAB’s lack of jurisdiction is apparent on the face of the complaint or petition.

4. How jurisdiction is determined

Republic v. Roman Catholic Archbishop, 685 SCRA 216 (2013)

It is axiomatic that the nature of an action and whether the tribunal has jurisdiction over such action are
to be determined from the material allegations of the complaint, the law in force at the time the
complaint is filed, and the character of the relief sought irrespective of whether the plaintiff is entitled
to all or some of the claims averred. Jurisdiction is not affected by the pleas or the theories set up by
defendant in an answer to the complaint or a motion to dismiss the same.

B. Allocation of jurisdiction

DBM Procurement Service v. Kolonwell Trading, 524 SCRA 591 (2007)

1. When act is done without jurisdiction, effects

Taglay v. Daray, G.R. No. 164258, August 22, 2012

C. Types/Classes of Jurisdiction

a. Original Concurrent Jurisdiction vis-a-vis Original Exclusive Jurisdiction

Pacific Asia Finance Ltd. (PAFIN) v. Yanigasawa, G.R. No. 175303, April 11, 2012

b. Appellate Jurisdiction v. Original Jurisdiction

Maslag v. Monzon, 698 SCRA 584

c. General Jurisdiction vis-a-vis Special or Limited Jurisdiction

Okol v. Slimmers World Internation, G.R. No. 160146, December 11, 2009.

d. Concurrent Jurisdiction

Pat-og, Sr. v. CSC, 697 SCRA 567

D. Court of Law and court of equity distinguished

In re: Petition for Separation of Property, Muller v. Muller, G.R. No. 149615, August 29, 2006

E. Court of Justice and Quasi-Judicial Bodies distinguished

Sps. Cripulo Ferrer and Engracia Puhawan v. CA, G.R. No. 190384, July 5, 2010

i. Adherence to jurisdiction, exception

G. Jurisdiction contradistinguished from Venue

Dacoycoy v. Intemediate Appelate Court, G.R. No. L-74854, April 2, 1991

Dolot v. Paje, G.R. No. 199199, August 27, 2019

i. venue and jurisdiction in criminal actions

Bonfacio v. RTC-Makati, G.R. No. 184800, May 5, 2010

H. Jurisdiction as determined by the presence of essential elements

1. Jurisdiction over the person or Jurisdiction in Personam

Macasaet v. Co, Jr., G.R. No. 156759, June 5, 2013

2. Jurisdiction over the subject matter or Jurisdiction in Rem

Padlan v. Sps. Dinglasan, G.R. No. 180321, March 20, 2013

People v. Estrebella, 164 SCRA 114

3. Jurisdictional Amount

A.M. No. 08-8-7-SC (The 2016 Revised Rules of Procedure for Small Claims Cases, Effective February 1,
2016)

Sections 19, 33 and 34 B.P. 129, as amended by R.A. No. 7691

Rule 141, ROC

Sps. Pajares v. Remarkable Laundry and Dry Cleaning, G.R. No. 212690, February 20, 2017