PANAY RAILWAYS vs.

HEVA MANAGEMENT
Doctrine: Payment of docket fees is an indispensable requirement for the perfection of an
appeal and before the court acquires jurisdiction over the same.

PRISCILLA JOSE vs RAMON JAVELLANA, et.al

Doctrine: The denial of a motion for reconsideration of an order granting the defending party’s
motion to dismiss is not an interlocutory but a FINAL ORDER because it puts an end to the particular
matter involved, or settles definitely the matter herein disposed of, as to leave nothing for the trial court
to do other than execute the order. Accordingly, the claiming party has a fresh period of 15 days from
notice of the denial within which to appeal the denial.

Fresh Period Rule- an adverse party appealing an adverse judgment/ final order is allowed a
fresh period of 15 days within which to file a notice of appeal from receipt of the order denying a motion
for reconsideration/ new trial.

Final vs Interlocutory Order: 1 st- disposes of the subject matter in its entirety leaving nothing
more to be done by the court.
Remedy: appeal under Rule 41

2nd- does not completely dispose the case but leaves something to be done
Remedy: special civil action for certiorari under Rule 65

TERESITA FABIAN vs DESIERTO

Doctrine: Section 27 of RA 6770 is unconstitutional. It cannot validly authorize an appeal to the
Supreme Court from decisions of the Ombudsman in administrative disciplinary cases. It violates the
proscription in Sec. 30, Art. 6 of the Constitution against a law which increased the appellate jurisdiction
of the SC.
Remedy: appeal to the CA under Rule 43

APO FRUITS CORP vs LANDBANK

Doctrine of Immutability of Judgment: As a rule, a final judgment may no longer be altered,
amended or modified, even if the alteration, amendment or modification is meant to correct what is
perceived to be an erroneous conclusion of fact or law and regardless of what court, be it the highest
Court of the land, rendered it.
In this case, it set aside the immutability of judgement rule because the land entitlement was
patently illegal. SC said they are duty bound to re-examine their own decision. Rules of procedure
should be used to help, secure, not override justice.

GLYNNA FORONDA-CRYSTAL vs. ANIANA LAWAS SON

Doctrine:
General rule: Jurisdiction is determined by the assessed value of the property as alleged in the
complaint.
Exception: If the assessed value of the property, while not alleged in the complaint, could still be
identified through facial examination of the documents already attached to the complaint.

In this case, the property involved has no assessed value but the property was only valued at P2, 826.
Applying the exception above, the MTC therefore has jurisdiction in the case and not the RTC.

Remedy: RTC must immediately dismiss the case for having no jurisdiction, without prejudice to the
parties’ filing of a new one before the MTC that has jurisdiction over the subject matter.

SALVADOR vs. MAPA

Doctrine: The averments in the complaint, not the nomenclature given by the parties, determine
the nature of the action. Although the petition was titled as Petition for Review on Certiorari, the SC
treated the petition under Rule 65 because it was alleged that the OMB committed grave abuse of
discretion.
The prescriptive period commenced from the date of the discovery of the offense in 1992,
hence the complaint filed on 1996 has not yet prescribed. The date of prescription shall be counted after
15 years from the discovery of the offense.

SPS. SABITSANA vs MUERTEGUI

Doctrine: The RTC has jurisdiction over the suit for quieting of title regardless of the assessed
value of the real property in dispute. This action is incapable of pecuniary estimation. This is under Rule
63 of the Rules of Court.
FIRST SARMIENTO PROPERTY HOLDINGS vs PHILIPPINE BANK
Doctrine: To determine the nature of the action, whether or not its subject matter is capable or
incapable of pecuniary estimation, the nature of the principal action or relief sought must be
ascertained. If the principal relief is for the recovery of a sum of money or real property, then the action
is capable of pecuniary estimation. However, if the principal relief sought is not for the recovery of sum
of money or real property, even if the claim over a sum of money or real property results as a
consequence of the principal relief, the action is incapable of pecuniary estimation.

ANTONIO PUNSALAN, JR vs LACSAMANA

Doctrine: The action for annulment of the deed of sale with damages is a real action affecting
title to or possession of the real property which under Sec. 2, Rule 4 of the Rules of Court should be tried
in the province where the property is situated.

ORBETA vs ORBETA
Doctrine: An action for cancellation of a real estate mortgage is a personal action since it is not
expressly included in the enumeration under Sec. 2, Rule 4 of the ROC. Similarly, an action to annul a
contract of loan and its accessory real estate mortgage is a personal action. Hence, where respondent
resides is the proper venue for the complaint to be filed.

TENORIO vs PANO
Doctrine: Where it is alleged that the contract has been breached, reason for which the other
party demands its resolution and the return of the property subject thereof, the action is an action for
the recovery of the possession of land and in accordance with Section 1, Rule 4,ROC, the action should
be filed where the property is situated.

UNITED CLAIMANTS ASSOC. vs. NEA

Doctrine: Evidently, the instant petition should have been filed with the RTC. However, as an
exception to this general rule, the principle of hierarchy of courts may be set aside for special and
important reasons. Such reason exists in the instant case involving as it does the employment of the
entire plantilla of NEA, more than 700 employees all told, who were effectively dismissed from
employment in one swift stroke. This to the mind of the Court entails its attention.

ARUEGO vs. CA
Doctrine: The jurisdiction of a court, whether in criminal or civil cases, once attached cannot be
ousted by subsequent happenings/ events, although of a character which would have prevented
jurisdiction from attaching in the first instance, and it retains jurisdiction until it finally disposes of the
case.

The action brought by Aruego for compulsory recognition and enforcement of successional
rights which was filed prior to the advent of the Family Code, must be governed by Article 285 of the
Civil Code and not by Article 175, paragraph 2 of the Family Code. The present law cannot be given
retroactive effect insofar as the instant case is concerned, as its application will prejudice the vested
right of private respondent to have her case decided under Article 285 of the Civil Code. The right was
vested to her by the fact that she filed her action under the regime of the Civil Code. Prescinding from
this, the conclusion then ought to be that the action was not yet barred, notwithstanding the fact that it
was brought when the putative father was already deceased, since private respondent was then still a
minor when it was filed, an exception to the general rule provided under Article 285 of the Civil Code.
Hence, the RTC, which acquired jurisdiction over the case by the filing of the complaint, never lost
jurisdiction over the same despite the passage of E.O. No. 209, also known as the Family Code of the
Philippines.

ENERIO vs ALAMPAY
Doctrine: The totality rule will apply.

The totality of the demand in suits for recovery of sums of money between the same parties constitutes
the basis of jurisdiction and for determining the jurisdictional amount. The claim for P978.00 actual
damages, P10,000 moral damages, P15,000 exemplary damages, and P3,000 AF fall within the
jurisdiction of the RTC.

FLORES vs MALLARE-PHILIPPS
Doctrine: In the case at bar, the lower court correctly held that the jurisdictional test is subject
to the rules on joinder of parties pursuant to Section 5 of Rule 2 and Section 6 of Rule 3 of the Rules of
Court and that, after a careful scrutiny of the complaint, it appears that there is a misjoinder of parties
for the reason that the claims against respondents Binongcal and Calion are separate and distinct and
neither of which falls within its jurisdiction.

TIJAM vs SIBONGHANOY
Doctrine: In Tijam, the defense of lack of jurisdiction was raised for the first time in a motion to
dismiss filed by the Surety almost fifteen (15) years after the questioned ruling had been rendered. At
several stages of the proceedings, in the court a quo as well as in the Court of Appeals, the Surety
invoked the jurisdiction of the said courts to obtain affirmative relief and submitted its case for final
adjudication on the merits. It was only when the adverse decision was rendered by the Court of Appeals
that it finally woke up to raise the question of jurisdiction.

Tijam applies only to exceptional circumstances. The general rule remains: a court’s lack of
jurisdiction may be raised at any stage of the proceedings even on appeal.
Estoppel by laches may be invoked to bar the issue of lack of jurisdiction only in cases in which
the factual milieu is analogous to that in the cited case.

REPUBLIC vs BANTIGUE
Doctrine: petitioner Republic is not estopped from questioning the jurisdiction of the lower
court, even if the former raised the jurisdictional question only on appeal.
Here, petitioner Republic filed its Opposition to the application for registration when the records
were still with the RTC. At that point, petitioner could not have questioned the delegated jurisdiction of
the MTC, simply because the case was not yet with that court. When the records were transferred to
the MTC, petitioner neither filed pleadings nor requested affirmative relief from that court. On appeal,
petitioner immediately raised the jurisdictional question in its Brief. Clearly, the exceptional doctrine of
estoppel by laches is inapplicable to the instant appeal. In this case, petitioner Republic has not
displayed such unreasonable failure or neglect that would lead us to conclude that it has abandoned or
declined to assert its right to question the lower court's jurisdiction.

MANCHESTER DEVELOPMENT CORP. vs CA

Doctrine: The Court cannot close this case without making the observation that it frowns at the
practice of counsel who filed the original complaint in this case of omitting any specification of the
amount of damages in the prayer although the amount of over P78 million is alleged in the body of the
complaint. This is clearly intended for no other purpose than to evade the payment of the correct filing
fees if not to mislead the docket clerk in the assessment of the filing fee.

All complaints, petitions, answers and other similar pleadings should specify the amount of
damages being prayed for not only in the body of the pleading but also in the prayer, and said damages
shall be considered in the assessment of the filing fees in any case. Any pleading that fails to comply
with this requirement shall not bib accepted nor admitted, or shall otherwise be expunged from the
record.

The Court acquires jurisdiction over any case only upon the payment of the prescribed docket fee. An
amendment of the complaint or similar pleading will not thereby vest jurisdiction in the Court, much less
the payment of the docket fee based on the amounts sought in the amended pleading.

SUN INSURANCE vs. ASUNCION

Doctrine: In the present case, a more liberal interpretation of the rules is called for considering
that, unlike Manchester, private respondent demonstrated his willingness to abide by the rules by
paying the additional docket fees as required. Thus, the Court rules as follows:

1. It is not simply the filing of the complaint or appropriate initiatory pleading, but the payment of the
prescribed docket fee, that vests a trial court with jurisdiction over the subject matter or nature of the
action. Where the filing of the initiatory pleading is not accompanied by payment of the docket fee, the
court may allow payment of the fee within a reasonable time but in no case beyond the applicable
prescriptive or reglementary period.

2. The same rule applies to permissive counterclaims, third party claims and similar pleadings, which
shall not be considered filed until and unless the filing fee prescribed therefor is paid. The court may also
allow payment of said fee within a reasonable time but also in no case beyond its applicable prescriptive
or reglementary period.

3. Where the trial court acquires jurisdiction over a claim by the filing of the appropriate pleading and
payment of the prescribed filing fee but, subsequently, the judgment awards a claim not specified in the
pleading, or if specified the same has been left for determination by the court, the additional filing fee
therefor shall constitute a lien on the judgment. It shall be the responsibility of the Clerk of Court or his
duly authorized deputy to enforce said lien and assess and collect the additional fee.

TACAY vs RTC of TAGUM

Doctrine: Where the action involves real property and a related claim for damages as well, the
legal fees shall be assessed on the basis of both (a) the value of the property and (b) the total amount of
related damages sought. The Court acquires jurisdiction over the action if the filing of the initiatory
pleading is accompanied by the payment of the requisite fees, or, if the fees are not paid at the time of
the filing of the pleading, as of the time of full payment of the fees within such reasonable time as the
court may grant, unless, of course, prescription has set in the meantime.
But where-as in the case at bar-the fees prescribed for an action involving real property have
been paid, but the amounts of certain of the related damages (actual, moral and nominal) being
demanded are unspecified, the action may not be dismissed. The Court undeniably has jurisdiction over
the action involving the real property, acquiring it upon the filing of the complaint or similar pleading
and payment of the prescribed fee. And it is not divested of that authority by the circumstance that it
may not have acquired jurisdiction over the accompanying claims for damages because of lack of
specification thereof. What should be done is simply to expunge those claims for damages as to which
no amounts are stated, which is what the respondent Courts did, or allow, on motion, a reasonable time
for the amendment of the complaints so as to allege the precise amount of each item of damages and
accept payment of the requisite fees therefor within the relevant prescriptive period.

LA SALETTE COLLEGE vs PILOTIN

Doctrine: It should be noted that full payment of the appellate docket fees within the prescribed
period is mandatory, even jurisdictional, for the perfection of the appeal. Otherwise, the appellate court
would not be able to act on the subject matter of the action, and the decision or final order sought to be
appealed from would become final and executory.

In the present case, petitioners insist that they seasonably paid the docket fees. After resolving thrice
the timeliness of the payment of the docket fees, the CA finally found that these had been paid one (1)
year and 11 days from the filing of their notice of appeal.

To recapitulate, on November 26, 1998, petitioners received the November 17, 1998 RTC Decision.
Consequently, they had 15 days to file their Notice of Appeal. They did so on November 26, 1998, but
failed to pay the docket fees. A review of the records shows that they paid these only on July 8, 1999, 23
or after almost seven (7) months from the mandated last day for payment, which was December 11,
1998. Clearly, the November 17, 1998 RTC Decision, which petitioners sought to appeal, had long
become final and executory.

HEIRS OF RUBEN REINOSO vs CA

Doctrine: In this case, it cannot be denied that the case was litigated before the RTC and said
trial court had already rendered a decision. While it was at that level, the matter of non-payment of
docket fees was never an issue. It was only the CA which motu propio dismissed the case for said
reason.

Considering the foregoing, there is a need to suspend the strict application of the rules so that the
petitioners would be able to fully and finally prosecute their claim on the merits at the appellate level
rather than fail to secure justice on a technicality, for, indeed, the general objective of procedure is to
facilitate the application of justice to the rival claims of contending parties, bearing always in mind that
procedure is not to hinder but to promote the administration of justice.

NG SOON vs ALDAY
Doctrine: While it may be that the body of petitioner's Complaint below was silent as to the
exact amount of moral and exemplary damages, and attorney's fees, the prayer did specify the amount
of not less than P50,000.00 as moral and exemplary damages, and not less than P50,000.00 as attorney's
fees. These amounts were definite enough and enabled the Clerk of Court of the lower Court to
compute the docket fees payable. Similarly, the principal amount sought to be recovered as "missing
money" was fixed at P900,000.00. The failure to state the rate of interest demanded was not fatal not
only because it is the Courts which ultimately fix the same, but also because Rule 141, Section 5(a) of the
Rules of Court, itemizing the filing fees, speaks of "the sum claimed, exclusive of interest." This clearly
implies that the specification of the interest rate is not that indispensable.

Factually, therefore, not everything was left to "guesswork" as respondent Judge has opined. The sums
claimed were ascertainable, sufficient enough to allow a computation pursuant to Rule 141, section 5(a).
PHIL. DAILY INQUIRER vs JUDGE ALAMEDA
Doctrine: In determining whether an initiatory pleading states a cause of action, "the test is as
follows: admitting the truth of the facts alleged, can the court render a valid judgment in accordance
with the prayer?
PROGRESSIVE DEVELOPMENT CORP vs CA
Doctrine: By its admission of a pending forcible entry case, it is obvious that private respondent
was indulging in forum shopping. While private respondent conveniently failed to inform the RTC that it
had likewise sought damages in the MTC on the basis of the same forcible entry, the fact remains that it
precisely did so, which stratagem was being duplicated in the second case. This is a compelling reason to
dismiss the second case.

ASIA DEVELOPMENT BANK vs GOODLAND

Doctrine: While the main relief sought in the Annulment Case (nullification of the REM) is
ostensibly different from the main relief sought in the Injunction Case (nullification of the extrajudicial
foreclosure and injunction against consolidation of title), the cause of action which serves as the basis
for the said reliefs remains the same — the alleged nullity of the REM. Thus, what is involved here is the
third way of committing forum shopping, i.e., filing multiple cases based on the same cause of action,
but with different prayers.

JUAN BAYANG vs CA
Doctrine: A long line of decisions has consistently held that for res judicata to apply: a) the
former judgment must be final; b) it must have been rendered by a court having jurisdiction over the
subject matter and the parties; c) it must be a judgment on the merits; and d) there must be between
the first case and the second case identity of parties, identity of subject matter and Identity of cause of
action.

Clearly, then, Civil Case No. 2589 is barred by the previous judgment in Civil Case No. 1892. This being
so, it should follow that the trial judge committed no grave abuse of discretion in deciding the latter case
by summary judgment.

PHIL. NUMISMATIC AND ANTIQUARIAN SOCIETY vs AQUINO, et. Al

Doctrine: Indeed, there was no proof submitted that Atty. Villareal was duly authorized by
petitioner to file the complaint and sign the verification and certification against forum shopping 43
dated December 21, 2009. Where the plaintiff is not the real party-in-interest, the ground for the
motion to dismiss is lack of cause of action. The reason for this is that the courts ought not to pass upon
questions not derived from any actual controversy. Truly, a person having no material interest to protect
cannot invoke the jurisdiction of the court as the plaintiff in an action. Nor does a court acquire
jurisdiction over a case where the real party- in- interest is not present or impleaded.

VIDAL vs ESCUETA
Doctrine: the time line in Section 417 should be construed to mean that if the obligation in the
settlement to be enforced is due and demandable on the date of the settlement, the six-month period
should be counted from the date of the settlement; otherwise, if the obligation to be enforced is due
and demandable on a date other than the date of the settlement, the six-month period should be
counted from the date the obligation becomes due and demandable.

By express provision of Section 417 of the LGC, an action for the enforcement of the settlement
should be instituted in the proper municipal or city court. This is regardless of the nature of the
complaint before the Lupon, and the relief prayed for therein. The venue for such actions is governed by
Rule 4, Section 1 of the 1997 Rules of Civil Procedure, as amended. An action for the enforcement of a
settlement is not one of those covered by the Rules on Summary Procedure in civil cases; 30 hence, the
rules on regular procedure shall apply, as provided for in Section 1, Rule 5 of the Rules of Civil
Procedure, as amended.

ARCELONA vs CA
Doctrine: it is logical that a tenant, in an action to establish his status as such, must implead all
the pro-indiviso co-owners; in failing to do so, there can be no final determination of the action. In other
words, a tenant who fails to implead all the coowners cannot establish with finality his tenancy over the
entire co-owned land.

Co-owners in an action for the security of tenure of a tenant are encompassed within the definition of
indispensable parties; thus, all of them must be impleaded.
 It is clear then that to set aside a final and executory judgment, there are three remedies
available to a litigant: first, a petition for relief from judgment under Rule 38 of the Rules of Court 25 on
grounds of fraud, accident, mistake and excusable negligence filed within sixty (60) days from the time
petitioner learns of the judgment but not more than six (6) months from the entry thereof; second, a
direct action to annul the judgment on the ground of extrinsic fraud; and third, a direct action for
certiorari or collateral attack to annul a judgment that is void upon its face or void by virtue of its own
recitals.

DAVID LU vs LU YM et al
Doctrine: In the current controversy, the main purpose of the complaint filed before the RTC
was the annulment of the issuance of the 600,000 LLDC shares of stocks because they had been
allegedly issued for less than their par value. Thus, David sought the dissolution of the corporation and
the appointment of receivers/management committee. To be sure, the annulment of the shares, the
dissolution of the corporation and the appointment of receivers/management committee are actions
which do not consist in the recovery of a sum of money. If, in the end, a sum of money or real property
would be recovered, it would simply be the consequence of such principal action. Therefore, the case
before the RTC was incapable of pecuniary estimation.

Even assuming that the subject in the instant case is capable of pecuniary estimation, still, the
case should not be dismissed because the insufficiency of the fees actually paid was belatedly raised;
David relied on the assessment made by the Clerk of Court; and if there is a deficiency, it may instead be
considered a lien on the judgment that may hereafter be rendered.

HARVEST ALL INVESTMENTS LTD vs ALLIANCE SELECT FOOD INTL

Doctrine:
This case is a precise illustration as to how an intra-corporate controversy may be classified as
an action whose subject matter is incapable of pecuniary estimation. Harvest All, et al. sought for the
nullity of the Alliance Board Resolution passed on May 29, 2015 which indefinitely postponed the
corporation's 2015 ASM pending completion of subscription to the SR0. Certainly, Harvest All, et al.'s
prayer for nullity, as well as the concomitant relief of holding the 2015 ASM as scheduled in the by-laws,
do not involve the recovery of sum of money. The mere mention of Alliance's impending SRO valued at
P1 Billion cannot transform the nature of Harvest All, et al.'s action to one capable of pecuniary
estimation, considering that: (a) Harvest All, et al. do not claim ownership of, or much less entitlement
to, the shares subject of the SRO; and (b) such mention was merely narrative or descriptive in order to
emphasize the severe dilution that their voting interest as minority shareholders would suffer if the
2015 ASM were to be held after the SRO was completed. If, in the end, a sum of money or anything
capable of pecuniary estimation would be recovered by virtue of Harvest All, et al.'s complaint, then it
would simply be the consequence of their principal action. Clearly therefore, Harvest All, et al.'s action
was one incapable of pecuniary estimation.