9.

Doctrine of non-interference / judicial stability

No court has the authority to interfere by injunction with the judgment of
another court of coordinate jurisdiction.
The doctrine of judicial stability or non-interference in the regular orders or
judgments of a co-equal court is an elementary principle in the administration of
justice: 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. The rationale for the rule is founded on the concept of
jurisdiction: a court that acquires jurisdiction over the case and renders judgment
therein has jurisdiction over its judgment, to the exclusion of all other coordinate
courts, for its execution and over all its incidents, and to control, in furtherance of
justice, the conduct of ministerial officers acting in connection with this judgment.
Thus, we have repeatedly held that a case where an execution order has
been issued is considered as still pending, so that all the proceedings on the
execution are still proceedings in the suit. A court which issued a writ of
execution has the inherent power, for the advancement of justice, to correct
errors of its ministerial officers and to control its own processes. To hold
otherwise would be to divide the jurisdiction of the appropriate forum in the
resolution of incidents arising in execution proceedings. Splitting of jurisdiction is
obnoxious to the orderly administration of justice.
To be sure, the law and the rules are not unaware that an issuing court
may violate the law in issuing a writ of execution and have recognized that there
should be a remedy against this violation. The remedy, however, is not the resort
to another co-equal body but to a higher court with authority to nullify the action
of the issuing court. This is precisely the judicial power that the 1987
Constitution, under Article VIII, Section 1, paragraph 2, speaks of and which this
Court has operationalized through a petition for certiorari, under Rule 65 of the
Rules of Court.
It is not a viable legal position to claim that a TRO against a writ of
execution is issued against an erring sheriff, not against the issuing Judge. A
TRO enjoining the enforceability of a writ addresses the writ itself, not merely the
executing sheriff. As already mentioned above, the appropriate action is to assail
the implementation of the writ before the issuing court in whose behalf the sheriff
acts, and, upon failure, to seek redress through a higher judicial body (Barroso v.
Omelio, G.R. No. 194767, October 14, 2015).

II. JURISDICTION
A. Classification of jurisdiction
1. Distinguish: original and appellate
Original jurisdiction is the power of the court to take judicial cognizance of
a case instituted for judicial action for the first time under conditions provided
by law. Appellate jurisdiction is the authority of the court higher in rank to re-
examine the final order or judgment of a lower court which tried the case and
now elevated for judicial review (Riano, Civil Procedure 2014 Ed.).

2. Distinguish: general and special

 General jurisdiction is the power to adjudicate all controversies, except
those expressly withheld from the plenary powers of the court. Special
jurisdiction is one which restricts the court’s jurisdiction only to particular
cases and subject to such limitations as may be provided by the governing
law (Riano, Civil Procedure 2014 Ed.).

3. Distinguish: exclusive and concurrent

Exclusive jurisdiction is the power to adjudicate a case or proceeding to
the exclusion of other courts at that stage. Concurrent jurisdiction or
sometimes referred to as the coordinate jurisdiction which is the power
conferred upon different courts whether of the same or different ranks, to take
cognizance at the state of the same case in the same or different judicial
territories (Riano, Civil Procedure 2014 Ed.).

B. Doctrines of hierarchy of courts and continuity of jurisdiction

The doctrine that requires respect for the hierarchy of courts was created by
the Supreme Court to ensure that every level of the judiciary performs its designated
roles in an effective and efficient manner.
Trial courts do not only determine the facts from the evaluation of the evidence
presented before them. They are likewise competent to determine issues of law
which may include the validity of an ordinance, statute, or even an executive
issuance in relation to the Constitution. To effectively perform these functions, they
are territorially organized into regions and then into branches. Their writs generally
reach within those territorial boundaries. Necessarily, they mostly perform the all-
important task of inferring the facts from the evidence as these are physically
presented before them. In many instances, the facts occur within their territorial
jurisdiction, which properly present the "actual case" that makes ripe a determination
of the constitutionality of such action. The consequences, of course, would be
national in scope. There are, however, some cases where resort to courts at their
level would not be practical considering their decisions could still be appealed before
the higher courts, such as the Court of Appeals.
The Court of Appeals is primarily designed as an appellate court that reviews the
determination of facts and law made by the trial courts. It is collegiate in nature. This
nature ensures more standpoints in the review of the actions of the trial court. But
the Court of Appeals also has original jurisdiction over most special civil actions.
Unlike the trial courts, its writs can have a nationwide scope. It is competent to
determine facts and, ideally, should act on constitutional issues that may not
necessarily be novel unless there are factual questions to determine.
The Supreme court, on the other hand, leads the judiciary by breaking new
ground or further reiterating - in the light of new circumstances or in the light of some
confusion of bench or bar - existing precedents. Rather than a court of first instance
or as a repetition of the actions of the Court of Appeals, this court promulgates these
doctrinal devices in order that it truly performs that role (The Diocese of Bacolod v.
Commission on Elections, G.R. No. 205728, January 21, 2015).

C. Jurisdiction of various Philippine courts (Bar 2007)

1. Supreme Court
(a) Exclusive original jurisdiction in petitions for certiorari, prohibition, and
mandamus against the:
i. CA
ii. COMELEC
iii. COA
iv. Sandiganbayan
v. CTA
(b) Concurrent original jurisdiction with the CA in petitions for certiorari,
prohibition, and mandamus against the:
i. RTC
ii. CSC
iii. CBAA
iv. NLRC
v. Other quasi-judicial agencies
(c) Appellate jurisdiction by way of petition for review on certiorari (appeal by
certiorari under Rule 45) against the:
i. CA
ii. Sandiganbayan
iii. RTC on pure questions of law and in cases involving the
constitutionality or validity of a law or treaty, international or executive
agreement, law, presidential decree, proclamation, order, instruction, ordinance
or regulation, legality of a tax, impost, assessment, toll or penalty, jurisdiction of a
lower court
iv. CTA in its decisions rendered en banc (Riano, Civil Procedure 2014
Ed.).

2. Court of Appeals
(1) Original jurisdiction to issue writs of mandamus, prohibition, certiorari,
habeas corpus, and quo warranto, and auxiliary writs or processes, whether
or not in aid of its appellate jurisdiction;
(2) Exclusive original jurisdiction over actions for annulment of judgment of
Regional Trial Courts; and
(3) Exclusive appellate jurisdiction over all final judgments, decisions,
resolutions, orders or awards of Regional Trial Courts and quasi-judicial
agencies, instrumentalities, boards or commissions, including the Securities
and Exchange Commission, the Social Security Commission, the Employees
Compensation Commission and the Civil Service Commission, except those
falling within the appellate jurisdiction of the Supreme Court in accordance
with the Constitution, the Labor Code of the Philippines under Presidential
Decree No. 442, as amended, the provisions of this Act, and of subparagraph
(1) of the third paragraph and subparagraph (4) of the fourth paragraph of
Section 17 of the Judiciary Act of 1948 (see B.P. 129, as amended).

3. Court of Tax Appeals (Bar 2006)

 Through the enactment of Republic Act No. 9282, the jurisdiction of the
CTA has been expanded to include not only civil tax cases but also cases that
are criminal in nature, as well as local tax cases, property taxes and final
collection of taxes.
Pursuant to the provisions of Republic Act No. 1125 and other laws prior
to R.A. 9282, the Court of Tax Appeals retains exclusive appellate jurisdiction to
review by appeal, the following:
(a) Decisions of the Commissioner of Internal Revenue in cases involving
disputed assessments, refunds of internal revenue taxes, fees or other
charges, penalties imposed in relation thereto, or other matters arising
under the National Internal Revenue Code or other law or part of law
administered by the Bureau of Internal Revenue;

(b) Decisions of the Commissioner of Customs in cases involving liability

for customs duties, fees or other money charges; seizure, detention or
release of property affected; fines, forfeitures or other penalties imposed in
relation thereto; or other matters arising under the Customs Law or other
law or part of law administered by the Bureau of Customs [Rep. Act. No.
1125, (1954), Sec. 7];

(c) In automatic review cases where such decisions of the Commission of

Customs favorable to the taxpayer is elevated to the Secretary of Finance
(Sec. 2315, TCC); and

(d) Decisions of the Secretary of Trade and Industry, in the case of non-
agricultural product, commodity or article, or the Secretary of Agriculture,
in the case of agricultural product, commodity or article, in connection with
the imposition of the Anti-Dumping Duty, Countervailing and Safeguard
Duty [Republic Act Nos. 8751 and 8752, (1999) Sec. 301 (a) and (p), and
Republic Act 8800].

Under Republic Act Number 9282, the CTA's original appellate jurisdiction
was expanded to include the following:
(a) Criminal cases involving violations of the National Internal Revenue
Code and the Tariff and Customs Code;

(b) Decisions of the Regional Trial Courts (RTC) in local tax cases;

(c) Decisions of the Central Board of Assessment Appeals (CBAA) in

cases involving the assessment and taxation of real property; and

(d) Collection of internal revenue taxes and customs duties the

assessment of which have already become final
(http://cta.judiciary.gov.ph).

4. Sandiganbayan
 The jurisdiction of the Sandiganbayan is perhaps one of the most often
amended provision from the 1973 Constitution to RA 8249 of 1997. Before RA
8249, jurisdiction of the Sandiganbayan was determined on the basis of the
penalty imposable on the offense charged. Then, it was amended such that
regardless of the penalty, so long as the offense charged was committed by a
public officer, the Sandiganbayan was vested with jurisdiction. Under RA 8249, to
determine whether the Sandiganbayan has jurisdiction, lawyers must look into
two (2) criteria, namely:
The nature of the offense and the salary grade of the public official.
Thus, Sec.4 of RA 8249 provides that the Sandiganbayan shall have
original exclusive jurisdiction over:
I.) Violations of RA 3019 (Anti-graft and Corrupt Practices Law);

II.) RA 1379 (Forfeiture of Illegally Acquired Wealth);

III.) Crimes by public officers or employees embraced in Ch. II, Sec.2

Title VII, Bk. II of the RPC (Crimes committed by Public Officers) namely:
a) Direct Bribery under Art. 210 as amended by BP 871, May 29,
1985;
b) Indirect Bribery under Art. 211 as amended by BP 871, May 29,
1985;
c) Qualified Bribery under Art. 211-A as amended by RA 7659, Dec.
13, 1993;
d) Corruption of public officials under Art. 212
where one or more of the accused are officials occupying the following
positions in the government whether in a permanent, acting or interim
capacity, at the time of the commission of the offense:
1) Officials of the executive branch occupying the positions of regional
director and higher, otherwise classified as Grade 27 and higher, of the
Compensation and Position Classification Act of 1989 Republic Act No.
6758) specifically including:
a) Provincial governors, vice-governors, members of the
sangguniang panlalawigan, provincial treasurers, assessors, engineers
and other provincial department heads;
b) City mayors, vice-mayors, members of the sangguniang
panglungsod, city treasurers, assessors, engineers and other department
heads;
c) Officials of the diplomatic service occupying the position of consul
and higher;
d) Philippine Army and Air force colonels, naval captains and all
officers of higher rank;
e) Officers of the PNP while occupying the position of Provincial
Director and those holding the rank of Senior Superintendent or higher;
f) City and provincial prosecutors and their assistants; officials and
the prosecutors in the Office of the Ombudsman and special prosecutor;
 g) President, directors or trustees or managers of government owned
or controlled corporations, state universities or educational institutions or
foundations;

2) Members of Congress and Officials thereof classified as Grade 27

and up under the Compensation and Classification Act of 1989;
3) Members of the Judiciary without prejudice to the provision of the
Constitution;
4) Chairmen and members of Constitutional Commissions, without
prejudice to the provision of the Constitution;
5) All other national and local officials classified as Grade 27 and higher
under the Compensation and Position Classification Act of 1989.

IV.) Other offenses or felonies whether simple or complexed with other

crimes committed in relation to their office by the public officials and
employees mentioned above;

V.) Civil and Criminal Cases filed pursuant to and in connection with EO 1,
2, 14 & 14-A issued in 1986

VI.) Petitions for issuance of Writ of mandamus, prohibition, certiorari,

habeas corpus, injunction and other ancillary writs and processes in aid of
its appellate jurisdiction; Provided, jurisdiction is not exclusive of the
Supreme Court

VII.) Petitions for Quo Warranto arising or that may arise in cases filed or
that may be filed under EO 1, 2, 14 & 14- A

VIII.) OTHERS provided the accused belongs to SG 27 or higher:

a.) Violation of RA 6713 - Code of Conduct and Ethical Standards
b.) Violation of RA 7080 - THE PLUNDER LAW
c.) Violation of RA 7659 - The Heinous Crime Law
d.) RA 9160 - Violation of The Anti-Money Laundering Law when
committed by a public officer

e.) PD 46 referred to as the gift-giving decree which makes it

punishable for any official or employee to receive directly or indirectly and
for the private person to give or offer to give any gift, present or other
valuable thing on any occasion including Christmas, when such gift,
present or valuable thing is given by reason of his official position,
regardless of whether or not the same is for past favors or the giver hopes
or expects to receive a favor or better treatment in the future from the
public official or employee concerned in the discharge of his official
functions. Included within the prohibition is the throwing of parties or
entertainment in honor of the official or employee or his immediate
relatives.
 f.) PD 749 which grants immunity from prosecution to any person who
voluntarily gives information about any violation of Art.210, 211 or 212 of
the RPC, RA 3019, Sec.345 of the NIRC, Sec. 3604 of the Customs and
Tariff Code and other provisions of the said Codes penalizing abuse or
dishonesty on the part of the public officials concerned and other laws,
rules and regulations penalizing graft, corruption and other forms of official
abuse and who willingly testifies against the public official or employee
subject to certain conditions.

It should be noted that private individuals can be sued in cases before the
Sandiganbayan if they are alleged to be in conspiracy with the public
officer.

The Sandiganbayan is vested with Appellate Jurisdiction over final

judgments, resolutions or orders of the RTC whether in the exercise of
their original or appellate jurisdiction over crimes and civil cases falling
within the original exclusive jurisdiction of the Sandiganbayan but which
were committed by public officers below Salary Grade 27
(http://sb.judiciary.gov.ph).