CASE DIGEST FOR JURISDICTION 3

1. Gomez vs. Montalban, G.R. No 174414, March 14, 2008

FACTS:
 Petitioner filed a Complaint with the RTC for a sum of money, damages and payment of attorney's fees
against respondent. The Complaint alleged, among other things, that: respondent obtained a loan from
petitioner in the sum of P40,000.00 with a voluntary proposal on her part to pay 15% interest per month;
upon receipt of the proceeds of the loan, respondent issued in favor of petitioner, as security, Capitol Bank
Check No. 0215632 in the sum of P46,000.00, covering the P40,000.00 principal loan amount and P6,000.00
interest charges for one month; when the check became due, respondent failed to pay the loan despite
several demands; thus, petitioner filed the Complaint praying for the payment of P238,000.00, representing
the principal loan and interest charges, plus 25% of the amount to be awarded as attorney's fees, as well as
the cost of suit.
 After considering the evidence presented by petitioner, the RTC rendered a Decision in his favor and ordered
the respondent to pay the petitioner the following amounts:
1. P40,000.00 representing the principal amount of the loan;
2. P57,600.00 representing interest at the rate of 24% per annum reckoned from August 26, 1998 until
the present;
3. P15,000.00 representing attorney's fees.
ISSUE:
 Whether or not the RTC has jurisdiction over the case?
RULING:
 Yes, the RTC has jurisdiction over the case.
 It is irrelevant that during the course of the trial, it was proven that respondent is only liable to petitioner for
the amount of P40,000.00 representing the principal amount of the loan; P57,000.00 as interest thereon at
the rate of 24% per annum; and P15,000.00 as attorney's fees. Contrary to respondent's contention,
jurisdiction can neither be made to depend on the amount ultimately substantiated in the course of the trial
or proceedings nor be affected by proof showing that the claimant is entitled to recover a sum in excess of
the jurisdictional amount fixed by law. Jurisdiction is determined by the cause of action as alleged in the
complaint and not by the amount ultimately substantiated and awarded.
 Jurisdiction over the subject matter of a case is conferred by law and determined by the allegations in the
complaint which comprise a concise statement of the ultimate facts constituting the plaintiff's cause of
action. The nature of an action, as well as which court or body has jurisdiction over it, is determined based
on the allegations contained in the complaint of the plaintiff, irrespective of whether or not the plaintiff is
entitled to recover upon all or some of the claims asserted therein. The averments in the complaint and the
character of the relief sought are the ones to be consulted. Once vested by the allegations in the complaint,
jurisdiction also remains vested irrespective of whether or not the plaintiff is entitled to recover upon all or
some of the claims asserted therein.

2. Paat vs. CA, G.R. No. 111107, January 10, 1997

FACTS:
 The truck of private respondent Victoria de Guzman while on its way to Bulacan was seized by the
Department of Environment and Natural Resources personnel in Aritao, Nueva Vizcaya because the driver
could not produce the required documents for the forest products found concealed in the truck.
 Petitioner Jovito Layugan, the Community Environment and Natural Resources Officer in Aritao, Cagayan,
issued an order of confiscation of the truck and gave the owner thereof fifteen (15) days within which to
submit an explanation why the truck should not be forfeited. Private respondents, however, failed to submit
the required explanation.
 Regional Executive Director Rogelio Baggayan of DENR sustained petitioner Layugan's action of confiscation
and ordered the forfeiture of the truck.
 Private respondents filed a letter of reconsideration which was, however, denied in a subsequent order.
 Subsequently, the case was brought by the petitioners to the Secretary of DENR.
  Pending resolution however of the appeal, a suit for replevin was filed by the private respondents against
petitioner Layugan and Executive Director Baggayan with the Regional Trial Court of Cagayan which issued a
writ ordering the return of the truck to private respondents.
 Petitioner Layugan and Executive Director Baggayan filed a motion to dismiss with the trial court contending,
inter alia, that private respondents had no cause of action for their failure to exhaust administrative
remedies.
 The trial court denied the motion to dismiss and their motion for reconsideration has also been denied.
 A petition for certiorari was filed by the petitioners with the respondent Court of Appeals which sustained
the trial court's order ruling that the question involved is purely a legal question.
ISSUE:
 Whether or not the RTC has jurisdiction over the case?
RULING:
 No, the RTC has no jurisdiction over the case.
 The doctrine of exhaustion of administrative remedies provides that before a party is allowed to seek the
intervention of the court, it is a pre-condition that he should have availed of all the means of administrative
processes afforded him. Hence, if a remedy within the administrative machinery can still be resorted to by
giving the administrative officer concerned every opportunity to decide on a matter that comes within his
jurisdiction then such remedy should be exhausted first before court's judicial power can be sought. The
premature invocation of court's intervention is fatal to one's cause of action. Accordingly, absent any finding
of waiver or estoppel the case is susceptible of dismissal for lack of cause of action.
 However, such doctrine may be disregarded when (1) when there is a violation of due process, (2) when the
issue involved is purely a legal question, (3) when the administrative action is patently illegal amounting to
lack or excess of jurisdiction, (4) when there is estoppel on the part of the administrative agency concerned,
(5) when there is irreparable injury, (6) when the respondent is a department secretary whose acts as an
alter ego of the President bears the implied and assumed approval of the latter, (7) when to require
exhaustion of administrative remedies would be unreasonable, (8) when it would amount to a nullification of
a claim, (9) when the subject matter is a private land in land case proceedings, (10) when the rule does not
provide a plain, speedy and adequate remedy, and (11) when there are circumstances indicating the urgency
of judicial intervention.
 In the case at bar, there is no question that the controversy was pending before the Secretary of DENR when
it was forwarded to him following the denial by the petitioners of the motion for reconsideration of private
respondents. In their letter of reconsideration, private respondents clearly recognize the presence of an
administrative forum to which they seek to avail, as they did avail, in the resolution of their case.

3. Tijam vs. Sibonghanoy, G.R. No. L-21450, April 15, 1968

FACTS:
 Barely one month after the effectivity of Republic Act No. 296 known as the Judiciary Act of 1948, the
petitioner spouses Serafin Tijam and Felicitas Tagalog filed a civil case in the Court of First Instance of Cebu
against the respondent spouses Magdaleno Sibonghanoy and Lucia Baguio to recover from them the sum of
P1,908.00, with legal interest thereon from the date of the filing of the complaint until the whole obligation
is paid, plus costs.
 As prayed for in the complaint, a writ of attachment was issued by the court against the respondents'
properties, but the same was soon dissolved upon the filing of a counter-bond by the respondents and the
Manila Surety and Fidelity Co., Inc. hereinafter referred to as the Surety.
 After trial upon the issues thus joined, the Court rendered judgment in favor of the petitioners and, after the
same had become final and executory. Upon motion of the latter, the Court issued a writ of execution
against the respondents.
 The writ having been returned unsatisfied, the plaintiffs moved for the issuance of a writ of execution
against the Surety's bond against which the Surety filed a written opposition upon two grounds, namely, (1)
Failure to prosecute and (2) Absence of a demand upon the Surety for the payment of the amount due
under the judgment.
  The Court denied the motion of the petitioners for the issuance of a writ of execution against the Surety’s
bond on the ground solely that no previous demand had been made on the Surety for the satisfaction of the
judgment.
 Thereafter the necessary demand was made, and upon failure of the Surety to satisfy the judgment, the
petitioners filed a second motion for execution against the counterbond. On the date set for the hearing
thereon, the Court, upon motion of the Surety's counsel, granted the latter a period of five days within which
to answer the motion. Upon its failure to file such answer, the Court granted the motion for execution and
the corresponding writ was issued.
 Subsequently, the Surety moved to quash the writ on the ground that the same was issued without the
required summary hearing provided for in the Rules of Court but the same was denied by the Court of First
Instance.
 The case was appealed to the Court of Appeals but the same was denied.
 However, five days after the Surety received notice of the decision, it filed a motion asking for extension of
time within which to file a motion for reconsideration which was granted by the CA. Two days later the
Surety filed a pleading entitled MOTION TO DISMISS, alleging substantially that petitioners’ action was filed
in the Court of First Instance of Cebu on July 19, 1948 for the recovery of the sum of P1,908.00 only; that a
month before that date Republic Act No. 296, otherwise known as the Judiciary Act of 1948, had already
become effective, Section 88 of which placed within the original exclusive jurisdiction of inferior courts all
civil actions where the value of the subject-matter or the amount of the demand does not exceed P2,000.00,
exclusive of interest and costs; that the Court of First Instance therefore had no jurisdiction to try and decide
the case.
 The Court of Appeals required the petitioners to answer the motion to dismiss, but they failed to do so.
Whereupon, the CA resolved to grant the motion filed by the respondents.
ISSUE:
 Whether or not the Court of First Instance has jurisdiction over the case?
RULING:
 Yes, the Court of First Instance has jurisdiction over the case.
 It is an undisputed fact that the action commenced by petitioners in the Court of First Instance of Cebu
against the Sibonghanoy spouses was for the recovery of the sum of P1,908.00 only — an amount within the
original exclusive jurisdiction of inferior courts in accordance with the provisions of the Judiciary Act of 1948
which had taken effect about a month prior to the date when the action was commenced. True also is the
rule that jurisdiction over the subject matter is conferred upon the courts exclusively by law, and as the lack
of it affects the very authority of the court to take cognizance of the case, the objection may be raised at any
stage of the proceedings.
 However, the Court ruled that the Surety is now barred by laches from invoking the plea for the purpose of
annulling everything done heretofore in the case with its active participation.
 The action was commenced in the Court of First Instance of Cebu on July 19, 1948, that is, almost fifteen
years before the Surety filed its motion to dismiss on January 12, 1963 raising the question of lack of
jurisdiction for the first time.
 A party may be estopped or barred from raising a question in different ways and for different reasons. Thus,
we speak of estoppel in pais, or estoppel by deed or by record, and of estoppel by laches.
 Laches, in a general sense is failure or neglect, for an unreasonable and unexplained length of time, to do
that which, by exercising due diligence, could or should have been done earlier; it is negligence or omission
to assert a right within a reasonable time, warranting a presumption that the party entitled to assert it either
has abandoned it or declined to assert it.
 The doctrine of laches or of "stale demands" is based upon grounds of public policy which requires, for the
peace of society, the discouragement of stale claims and, unlike the statute of limitations, is not a mere
question of time but is principally a question of the inequity or unfairness of permitting a right or claim to be
enforced or asserted.
 The facts of this case show that from the time the Surety became a quasi-party on July 31, 1948, it could
have raised the question of the lack of jurisdiction of the Court of First Instance of Cebu to take cognizance
of the present action by reason of the sum of money involved which, according to the law then in force, was
within the original exclusive jurisdiction of inferior courts. It failed to do so. Instead, at several stages of the
proceedings in the court a quo as well as in the Court of Appeals, it invoked the jurisdiction of said courts to
obtain affirmative relief and submitted its case for a final adjudication on the merits. It was only after an
adverse decision was rendered by the Court of Appeals that it finally woke up to raise the question of
jurisdiction. Were we to sanction such conduct on its part, We would in effect be declaring as useless all the
proceedings had in the present case since it was commenced on July 19, 1948 and compel the judgment
creditors to go up their Calvary once more. The inequity and unfairness of this is not only patent but
revolting.