Saturday, July 16, 2011

JURISDICTION OF THE FIRST LEVEL COURTS OUTSIDE METRO MANILA; and EXCEPTION TO THE PROSCRIPTION AGAINST AN AMENDMENT TO CONFER JURISDICTION TO THE COURT

            Section 19(8) of Batas Pambansa Blg. 129, also known as “The Judiciary Reorganization Act of 1980.” as amended by Republic Act No. 7691, or otherwise known as An Act Expanding the Jurisdiction of the Metropolitan Trial Courts, Municipal Trial Courts and Municipal Circuit Trial Courts, states:
         
“SEC. 19. Jurisdiction in civil cases. – Regional Trial Courts shall exercise exclusive original jurisdiction:

x x x x
           
(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 (P100,000.00) or, in such other cases in Metro Manila, where the demand, exclusive of the abovementioned items exceeds Two hundred thousand pesos (P200,000.00).”
           

Section 5 of Rep. Act No. 7691 further provides:
           
“SEC. 5. After five (5) years from the effectivity of this Act, the jurisdictional amounts mentioned in Sec. 19(3), (4), and (8); and Sec. 33(1) of Batas Pambansa Blg. 129 as amended by this Act, shall be adjusted to Two hundred thousand pesos (P200,000.00). Five (5) years thereafter, such jurisdictional   amounts shall be adjusted further to Three hundred thousand pesos (P300,000.00): Provided, however, That in the case of Metro Manila, the abovementioned jurisdictional amounts shall be adjusted after five (5) years from the effectivity of this Act to Four hundred thousand pesos (P400,000.00).”
Relative thereto, the Supreme Court Circular No. 21-99 which was issued declaring the first adjustment on the jurisdictional amount of first level courts or the MTCs outside of Metro Manila from P100,000.00 to P200,000.00 took effect on March 20, 1999.  
On the other hand, the second adjustment from P200,000.00 to P300,000.00 became effective on February 22, 2004 in accordance with OCA Circular No. 65-2004 issued by the Office of the Court Administrator on May 13, 2004. 
In Irene Sante vs. Hon. Claravall, the Supreme Court stated that since at the time of the filing of the complaint on April 5, 2004, the MTCC’s jurisdictional amount has already been adjusted to P300,000.00, there is no doubt that the Regional Trial Court (RTC) has jurisdiction over the case since the total amount of damages being claimed by the petitioner in the case was P420,000.00.

        Moreover, in the said case the Supreme Court found no error, much less grave abuse of discretion, on the part of the Court of Appeals in affirming the RTC’s order allowing the amendment of the original complaint from P300,000.00 to P1,000,000.00 despite the pendency of a petition for certiorari filed before the Court of Appeals
The High Court declared that while it is a basic jurisprudential principle that an amendment cannot be allowed when the court has no jurisdiction over the original complaint and the purpose of the amendment is to confer jurisdiction on the court (Siasoco v. Court of Appeals, G.R. No. 132753, February 15, 1999, 303 SCRA 186, 196), the RTC in the case clearly had jurisdiction over the original complaint and the amendment of the complaint was then still a matter of right under Section 2, Rule 10 of the Rules of Court.  Ergo, the amendment of the complaint was in order. (IRENE SANTE AND REYNALDOSANTE vs. HON. EDILBERTO T. CLARAVALL, G.R. No. 173915, February 22, 2010, VILLARAMA, JR., J.).


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