Jurisdiction of The Regional Trial Courts

Exclusive original jurisdiction of the RTC Under Sec. 19 of B.P. 129, as amended and other pertinent
provisions of the same law, the Regional Trial Courts shall exercise exclusive original jurisdiction over the
following cases:

1. All civil actions in which the subject of the litigation is incapable of pecuniary estimation;
2. All civil actions which involve title to, or possession of real property or an interest therein, where
the assessed value of such property involved exceeds P20,000 outside Metro Manila, or for civil
actions in Metro Manila where such value exceeds P50,000; Note: Excepted from the above rule
are actions for forcible entry and unlawful detainer of land or buildings, exclusive original
jurisdiction over which is conferred upon the MTC.
3. All actions in admiralty and maritime jurisdiction where the demand or claim exceeds P300,000
outside Metro Manila, or in Metro Manila, where such demand or claim exceeds P400,000. (Bar
2010)
4. All matters of probate, both testate and intestate, where the gross value of the estate exceeds
P300,000 outside Metro Manila or, in probate matters in Metro Manila, where such gross value
exceeds P400,000.
5. In all actions involving the contract of marriage and marital relations. Note: This jurisdiction is
deemed modified by Sec. 5 of R.A. 8369, the law which established the Family Courts. However,
under Sec. 17 of R.A. 8369, in areas where there are no Family Courts, the cases referred to in
Sec. 5 of the law shall be adjudicated by the Regional Trial Court.
6. All cases not within the exclusive jurisdiction of any court, tribunal, person or body exercising
judicial or quasijudicial functions Note: This jurisdiction is often described as the ‘general’
jurisdiction of the RTC making it a court of ‘general jurisdiction.’
7. All civil actions and special proceedings falling within the exclusive original jurisdiction of the
Juvenile and Domestic Relations Court and of the Court of Agrarian Relations as now provided
by law
8. All other cases in which the demand or the value of the property in controversy exceeds
P300,000 outside Metro Manila, or in Metro Manila where the demand exceeds P400,000,
exclusive of interest, damages of whatever kind, attorney’s fees, litigation expenses and costs.

Note: The jurisdiction of the RTC over cases under the exclusive original jurisdiction of the
Juvenile and Domestic Relations Court is subject to R.A. 8369, the law establishing Family courts.

Actions incapable of pecuniary estimation (Bar 1997; 2003; 2009) –

- one wherein the primary or principal relief sought is not a claim for a sum of money or the assertion
of title to or possession of personal or real property but some other primary or principal relief which
cannot be valued in monetary terms.
- Examples of actions incapable of pecuniary estimation are those for specific performance, support, or
foreclosure of mortgage or annulment of judgment; also actions questioning the validity of a mortgage,
annulling a deed of sale or conveyance and to recover the price paid and for rescission, which is a
counterpart of specific performance.

A simpler restatement of jurisprudence discloses that to determine if an action is one incapable of

pecuniary estimation, it is necessary to ascertain the nature of the principal remedy sought. If it is
primarily for the recovery of a sum of money, it is capable of pecuniary estimation. Jurisdiction over the
action would then depend upon the amount of the claim. Where the basic issue is something other than
the right to recover a sum of money, or the money claim is merely incidental to the principal relief, the
action is incapable of pecuniary estimation (Russel v. Vestil, 304 SCRA 739, 744; Barangay San Roque v.
Heirs of Pastor, 334 SCRA 127,132- 133).

1. An action for reformation of an instrument, rescission of a contract or an action for specific

performance are examples of actions incapable of pecuniary estimation.

2. A complaint for expropriation is incapable of pecuniary estimation. An expropriation suit does

not involve the recovery of money. Rather it deals with the exercise by the government of its
authority and right to take private property for public use (Barangay San Roque v. Heirs of
Pastor, 334 SCRA 127, 133). The subject of the expropriation suit is the government’s exercise of
eminent domain, a matter that is incapable of pecuniary estimation (Barangay San Roque, supra
at 134).

3. An action seeking to annul a resolution of a government-owned and controlled corporation is

an action incapable of pecuniary estimation (Polomolok Water District v. Polo- molok General
Consumers Association, Inc., 636 SCRA 647, 652-653).

4. An action to annul a Deed of Declaration of Heirs and for a partition of land with an assessed
value of P5,000.00 is an action incapable of pecuniary estimation where the partition aspect is
only incidental to the action for annulment. (Russel v. Vestil, 304 SCRA 739, 745-746).

The nature of the action is not determined by what is stated in the caption of the complaint but by the
allegations of the complaint and the relief prayed for. The ultimate objective of the complaint must be
inquired into. Hence, an action for reconveyance of real property will not be deemed one incapable of
pecuniary estimation where the ultimate objective is to obtain title to the property. “Where the ultimate
objective of the plaintiffs, x x x is to obtain title to real property, it should be filed in the proper court
having jurisdiction over the assessed value of the property subject thereof’ (Barangay Pipi v. Talip, 469
SCRA 409, 413).

5. An action for the annulment of an extrajudicial foreclosure sale of real property with an
assessed value of P50,000 located in Laguna is incapable of pecuniary estimation (Bar 2000).
6. An action for partition of a real property located in Taytay, Rizal and with an assessed value of
P20,000, the resolution of which involves the determination of hereditary rights, is an action
incapable of pecuniary estimation and thus, should be filed in the Regional Trial Court
(Suggested Answer, UP Law Center, Bar2000).
Note: This situation could also involve an answer more consistent with current laws on jurisdiction. It
could be argued that an action for partition of real property is one which involves interest in real
property. Hence, jurisdiction would be dependent on the assessed value of the property.

7. An action for specific performance to compel the defendant to execute a deed of conveyance
covering a parcel of land with an assessed value of P19,000.00 is an action incapable of
pecuniary estimation and is cognizable by the Regional Trial Court because the main issue is
whether or not there is a right to compel specific performance (Suggested Answer, UP Law
Center, Bar 2003).

Note: This answer is subject to an alternative answer which asserts that where the primary purpose of
the action is to recover or obtain ownership of the real property, the action is one affecting title to real
property and is therefore, a real action. In a real action, jurisdiction is determined by the assessed value
of the property and hence, because the assessed value under the facts is P19,000.00 the action is within
the jurisdiction of the MTC.

8. An action for specific performance is one generally considered incapable of pecuniary

estimation (Russel v. Vestil, 304 SCRA 738, 745)
9. An action for a writ of injunction is within the jurisdiction of the Regional Trial Court. It is an
action incapable of pecuniary estimation (Bar 1997, No. l[b]; Bar 2009)

Under R.A. 8369, the Family Courts shall have exclusive original jurisdiction over the following civil
cases:

1. Petitions for guardianship, custody of children and habeas corpus involving children;

2. Petitions for adoption for children and the revocation thereof;

3. Complaints for annulment of marriage, declaration of nullity of marriage and those relating to status
and property relations of husband and wife or those living together under different status and
agreements, and petitions for dissolution of conjugal partnership of gains;

4. Petitions for support and/or acknowledgment;

5. Summary judicial proceedings brought under the

provisions of Executive Order No. 209, otherwise known as the

“Family Code of the Philippines;”

6. Petitions for declaration of status of children as abandoned, dependent or neglected children,

petitions for voluntary or involuntary commitment of children, the suspension, termination or
restoration of parental authority and other cases cognizable under P.D. 603, E.O. 56 (series of 1986) and
other related laws;

7. Petitions for the constitution of the family home;

8. Cases against minors cognizable under the Dangerous Drugs Act, as amended;

9. Violations of R.A. 7610, otherwise known as the “Special Protection of Children Against Child Abuse,
Exploitation and Discrimination Act;” and
10. Cases of domestic violence against:

a. Women — which are acts of gender based violence that results, or are likely to result in physical,
sexual or psychological harm or suffering to women; and other forms of physical abuse such as battering
or threats and coercion which violate a woman’s personhood, integrity and freedom movement; and

b. Children — which include the commission of all forms of abuse, neglect, cruelty, exploitation,
violence, and discrimination and all other conditions prejudicial to their development.

If an act constitutes a criminal offense, the accused or batterer shall be subject to criminal proceedings
and the corresponding penalties. If any question involving any of the above matters should arise as an
incident in any case pending in the regular courts, said incident shall be determined in that court (Sec. 5,
RA. 8369).

In areas where there are no Family Courts, the aboveenumerated cases shall be adjudicated by the
Regional Trial Court (Sec. 17, RA. 8369).

In a personal action, the plaintiff seeks the recovery of personal property, the enforcement of a
contract, or the recovery of damages.

Real actions, on the other hand, are those affecting title to or possession of real property, or interest
therein. As a personal action based upon an oral contract, Article 1145 providing a prescriptive
30

period of six years applies in this case instead.

An actionable document refers to a written instrument or document that serves as the basis of a
legal action or defense in court. It is a document that provides evidence of a right or obligation
and can be directly relied upon to establish a party's claim or defense in a legal proceeding.

For example:

 Contracts: Written agreements between parties that outline obligations and rights, such
as a lease agreement, employment contract, or sales contract.
 Deeds: Documents that transfer ownership of property, such as a deed of sale or deed of
donation.
 Promissory Notes: Written promises to pay a certain sum of money to another party,
which can be the basis for a claim of payment.
The Statute of Frauds is a legal principle that requires certain types of contracts and agreements to be in
writing and signed by the parties involved to be enforceable in court. The primary purpose of the Statute
of Frauds is to prevent fraudulent claims and misunderstandings that might arise from oral agreements.
By requiring a written document, the law seeks to ensure that there is clear and verifiable evidence of
the agreement and its terms.

Case Title: G.R. No. 212472

SPECIFIED CONTRACTORS & DEVELOPMENT, INC., AND SPOUSES ARCHITECT ENRIQUE O. OLONAN AND
CECILIA R. OLONAN, Petitioners

vs.

JOSE A. POBOCAN , Respondent

*Specified Contractors & Development Inc., et al. vs. Jose A. Pobocan*

Jurisdiction in Civil Actions and Prescription of Actions

Facts:

- Respondent, Jose A. Pobocan, was employed by Specified Contractors & Development Inc. until his
retirement in March 2011, having served as president of the company and its subsidiaries.

- An oral agreement was allegedly made between respondent and Architect Enrique Olonan, chairman
of Specified Contractors, promising respondent one unit per building constructed as part of his
compensation.

- The buildings in question were Xavierville Square Condominium in Quezon City and Sunrise Holiday
Mansion Building I in Cavite. Respondent demanded the execution of deeds of assignment for Unit 708
of Xavierville Square Condominium and Unit 208 of Sunrise Holiday Mansion Bldg. I.

- Upon refusal, respondent filed a complaint for specific performance with the Regional Trial Court (RTC)
of Quezon City on November 21, 2011, seeking the conveyance of the units and payment of damages.

Procedural History:

1. RTC Decision (June 4, 2012): Granted the motion to dismiss by the petitioners, ruling that the action
was barred by the statute of frauds and that the oral agreement should have been in writing.

2. CA Decision (November 27, 2013): Reversed the RTC decision, holding that the statute of frauds did
not apply to partially performed contracts and that the case should proceed to trial.

3. Supreme Court Petition: Petitioners challenged the CA decision, raising issues of jurisdiction,
prescription, and the applicability of the statute of frauds.
Issues:

1. Jurisdiction: Whether the RTC had jurisdiction over the case, considering the allegations in the
complaint related to an employer-employee relationship.

2. Prescription: Whether the respondent’s cause of action had already prescribed.

3. Statute of Frauds: Whether the action was barred by the statute of frauds.

Ruling:

1. Jurisdiction: The Supreme Court ruled that the action was for specific performance, a personal action
over which the RTC had jurisdiction. Although the subject matter involved real property, the crux of the
issue was the enforcement of an oral contract, not the title or possession of the property. The claim did
not arise out of an employer-employee relationship, so the labor arbiter did not have jurisdiction.

2. Prescription: The Court found that the action for specific performance was already barred by
prescription. The oral agreements cited by the respondent dated back to 1994 and 1999, and the action
was filed in 2011, well beyond the six-year prescriptive period for oral contracts.

3. Statute of Frauds: The Court noted that since the action was already prescribed, there was no need to
address the applicability of the statute of frauds.

Disposition:

- The Supreme Court GRANTED the petition, reversing and setting aside the CA decision. The complaint
was dismissed on the ground of prescription.

Key Takeaway:

- Jurisdiction in civil cases is determined by the nature of the action and the allegations in the complaint.
Personal actions, like specific performance, are within the RTC's jurisdiction even when the subject
matter involves real property.

- Actions based on oral contracts must be filed within the six-year prescriptive period, emphasizing the
importance of timely legal action.

An action in personam is an action against a person on the basis of his personal liability.

An action in rem is an action against the thing itself instead of against the person.

An action quasi in rem is one wherein an individual is named as defendant and the purpose of the
proceeding is to subject his interest therein to the obligation or lien burdening the property (Asiavest
Limited v. Court of Appeals, 296 SCRA 539, 552) purpose is to affect interests of particular persons in a
thing

I. Jurisdiction
 Jurisdiction is the authority of a tribunal to hear and decide a case. In Conflict of Laws,
Jurisdiction is the power of the state to create legal interests which other states will
recognize and enforce.

Kinds of Jurisdiction:

Jurisdiction Over the Subject Matter

Jurisdiction over the subject matter is conferred by law and is defined as the authority of a court to hear
and decide cases of the general class to which the proceedings in question belong.
Jurisdiction over the subject-matter is acquired by concession of the sovereign authority which
organizes a court and determines the nature and extent of its powers in general and thus fixes its
jurisdiction with reference to actions which it may entertain and the relief it may grant.

• Power to hear and determine cases of general class to which the proceedings in question belong.

• It is conferred by the sovereign authority, which organizes the courts and defines it powers.

• Jurisdiction over subject matter is fixed by law and cannot be conferred by consent of the parties or
their voluntary submission. (Davao Light v. Court of Appeals, G.R. No. 111685 2001

Jurisdiction Over Persons

 summons by publication (Secs. 16, 17, 18, Rule 124, Rules of Court). This manner of summons is
good only if the action is in rem or quasi in rem (Sec. 17) or involves the personal status of the
plaintiff

It is the competence of a court to render decision that will bind the parties to the suit.
Jurisdiction Over the Res

 jurisdiction may for instance be acquired by coercive seizure of the property by attachment
proceedings.

It is the jurisdiction over the subject matter of the controversy, regardless of the persons who may be
interested therein. It may be classified as follows:

(a) Action in Rem – purpose is to affect the interests of all persons in a thing, thus the court of the forum
may render judgment as long as it has jurisdiction over the res. Status of a thing

(b) Quasi in Rem – purpose is to affect interests of particular persons in a thing, thus the court of the
forum may render judgment as long as it has jurisdiction over said persons. Examples of actions quasi in
rem: (a) action for partition; (b) action for accounting.

(c) Action in Personam – purpose is to impose personal liability upon the defendant

An action to foreclose a real estate mortgage against a non-resident defendant who is not found in the
Philippines is Quasi in rem- quieting of title, attachment proceeding, An action for annulment of
certificate of title is Quasi in rem

An action quasi in rem is one wherein an individual is named as defendant and the purpose of the
proceeding is to subject his interest therein to the obligation or lien burdening the property

Forfeiture proceedings are Action in Rem. Probate, annulment

An action for a sum of money, damages, specific performance, forcible is an Action In personam.
Action to recover property, unlawful detainer, ejectment

The proceeding for the allowance or probate of a will is an In rem proceeding.

Reckless imprudence- not in personam because it is no longer civil

Real action- a real action is an action affecting title to real property, or for the recovery of possession,
or for partition or condemnation of, or foreclosure of mortgage on, real property

Personal- An action for the declaration of nullity of a marriage is a personal action

Mixed action

A land registration case is a proceeding In rem , and jurisdiction over the res, in this case, cannot be
acquired, unless there is a constructive seizure of the land through publication and service (Republic
vs. Herbieto, 459 SCRA 183). The seizure in this case, is not an actual seizure of the land.

Original jurisdiction is the power of a court to hear and decide a case for the first time,

Exclusive jurisdiction means that only one specific court has the authority to hear and decide on certain
types of cases. No other court can hear cases of this particular nature.

Appellate jurisdiction refers to the power of a court to review, modify, or overturn decisions made by a
lower court.
Section 19. Jurisdiction in civil cases. – Regional Trial Courts shall exercise exclusive original
jurisdiction:

(1) In all civil actions in which the subject of the litigation is incapable of pecuniary
estimation;

(2) In all civil actions which involve the title to, or possession of, real property, or any
interest therein, where the assessed value of the property involved exceeds Twenty
thousand pesos (P20,000.00) or for civil actions in Metro Manila, where such the
value exceeds Fifty thousand pesos (50,000.00) except actions for forcible entry into
and unlawful detainer of lands or buildings, original jurisdiction over which is
conferred upon Metropolitan Trial Courts, Municipal Trial Courts, and Municipal
Circuit Trial Courts;

(3) In all actions in admiralty and maritime jurisdiction where he demand or claim
exceeds One hundred thousand pesos (P100,000.00) or , in Metro Manila, where
such demand or claim exceeds Two hundred thousand pesos (200,000.00);

(4) In all matters of probate, both testate and intestate, where the gross value of the
estate exceeds One hundred thousand pesos (P100,000.00) or, in probate matters in
Metro Manila, where such gross value exceeds Two hundred thousand pesos
(200,000.00);

(5) In all actions involving the contract of marriage and marital relations;

(6) In all cases not within the exclusive jurisdiction of any court, tribunal, person or
body exercising jurisdiction or any court, tribunal, person or body exercising judicial
or quasi-judicial functions;

(7) In all civil actions and special proceedings falling within the exclusive original
jurisdiction of a Juvenile and Domestic Relations Court and of the Courts of Agrarian
Relations as now provided by law; and

(8) In all other cases in which the demand, exclusive of interest, damages of
whatever kind, attorney's fees, litigation expenses, and costs or the value of the
property in controversy exceeds One hundred thousand pesos (100,000.00) or, in
such other abovementioned items exceeds Two hundred thousand pesos
(200,000.00). (as amended by R.A. No. 7691*)

Section 20. Jurisdiction in criminal cases. – Regional Trial Courts shall exercise exclusive original
jurisdiction in all criminal cases not within the exclusive jurisdiction of any court, tribunal or body,
except those now falling under the exclusive and concurrent jurisdiction of the Sandiganbayan which
shall hereafter be exclusively taken cognizance of by the latter.

Section 21. Original jurisdiction in other cases. – Regional Trial Courts shall exercise original
jurisdiction:
 (1) In the issuance of writs of certiorari, prohibition, mandamus, quo warranto,
habeas corpus and injunction which may be enforced in any part of their respective
regions; and

(2) In actions affecting ambassadors and other public ministers and consuls.

Section 22. Appellate jurisdiction. – Regional Trial Courts shall exercise appellate jurisdiction over
all cases decided by Metropolitan Trial Courts, Municipal Trial Courts, and Municipal Circuit Trial
Courts in their respective territorial jurisdictions. Such cases shall be decided on the basis of the
entire record of the proceedings had in the court of origin and such memoranda and/or briefs as may
be submitted by the parties or required by the Regional Trial Courts. The decision of the Regional
Trial Courts in such cases shall be appealable by petition for review to the

Court of Appeals which may give it due course only when the petition shows prima facie that the
lower court has committed an error of fact or law that will warrant a reversal or modification of the
decision or judgment sought to be reviewed.