Jurisdiction of The RTC

JURISDICTION OF THE
REGIONAL TRIAL
COURTS
Marie Immaculate L. Clemente

EXCLUSIVE ORIGINAL JURISDICTION
1. Actions in which the subject of litigation is incapable of pecuniary

estimation;
2. Actions involving title to or possession of real property or any

interest therein where the assessed value exceeds Php 20,000 or
Php 50,000 in Metro Manila, except forcible entry and unlawful
detainer;
3. Actions in admiralty and maritime jurisdiction where demand or

claim exceeds Php 300,000 or Php 400,000 in Metro Manila;
4. Matters of probate, testate or intestate, where gross value of estate

exceeds Php 300,000 or Php 400,000 in Metro Manila;
EXCLUSIVE ORIGINAL JURISDICTION
5. In all actions involving the contract of marriage and marital

relations;
6. Cases not within the exclusive jurisdiction of any court , tribunal,

person or body exercising judicial or quasi-judicial function;
7. Civil actions and special proceedings falling within exclusive

original jurisdiction of Juvenile and Domestic Relations Court and
Court of Agrarian Reforms;
8. Other cases where the demand, exclusive of interest , damages,

attorney ’s fees, litigation expenses and costs, or value of property in
controversy exceeds P300,000 or Php 400,000 in Metro Manila; and
9. Intra-corporate controversies under Sec. 5.2 of the Securities and

Regulation Code.
CONCURRENT JURISDICTION
• With the SC, SB, and CA

1. Writ of Amparo
2. Writ of Habeas Data
• With the SC
Actions affecting ambassadors and other public ministers and consuls.
• With SC and CA
1. Certiorari, prohibition and mandamus against lower courts and
bodies;
2. Habeas corpus and Quo Warranto;
• With the MTC

Cases involving enforcement or violations of environmental and other
related laws, rules and regulations.
APELLATE JURISDICTION
1. Over all cases decided by the Metropolitan Trial Courts,

Municipal Trial Courts, and Municipal Circuit Trial Courts in
their respective territorial jurisdictions.
2. Decisions of the RTC in the exercise of its appellate

jurisdiction shall be appealable by petition for review to the
CA.
SPECIAL JURISDICTION
SC may designate certain branches of RTC to try

exclusively criminal cases, juvenile and domestic
relations cases, agrarian cases, urban land reform
cases not falling within the jurisdiction of any quasi-
judicial body and other special cases in the interest of
justice
JURISDICTION OVER INTRA -CORPORATE
CONTROVERSIES
1. Devices or schemes employed by, or any act of, the board of

directors, business associates, officers or partners, amounting to
fraud or misrepresentation which may be detrimental to the interest
of the public and/or of the stockholders, partners, or members of any
corporation, partnership, or association;
2. Controversies arising out of intra-corporate, partnership, or

association relations, between and among stockholders, members, or
associates; and between, any or all of them and the corporation,
partnership, or association of which they are stockholders, members,
or associates, respectively ;
JURISDICTION OVER INTRA -CORPORATE
CONTROVERSIES
3. Controversies in the election or appointment of directors, trustees,

officers, or managers of corporations, partnerships, or associations;
4. Derivative suits; and
5. Inspection of corporate book

T WO TESTS IN DETERMINING WHETHER OR NOT THE
CONTROVERSY INVOLVES INTRA -CORPORATE ISSUES:
1. The Relationship Test

2. Nature of the Controversy Test
1. The Relationship Test
1. Between the corporation, partnership or association and the

public;
2. Between the corporation, partnership or association and the

State insofar as its franchise, permit or license to operate is
concerned;
3. Between the corporation, partnership or association and

its stockholders, partners, members or officers; and
4. Among the stockholders, partners or associates themselves .

2. Nature of the Controversy Test
Controversy not only rooted in the existence of intra-

corporate relationship, but also to the enforcement of parties’
correlative rights and obligations under the Corporation Code or
rules of the corporation .
MEDICAL PLAZA MAKATI CONDOMINIUM
CORPORATION VS. CULLEN
FACTS:
 Respondent Robert H. Cullen purchased from MLHI condominium

Unit No. 1201 of the Medical Plaza Makati.
 On September 19, 2002, petitioner, through its corporate secretary,
Dr. Jose Giovanni E. Dimayuga, demanded from respondent payment
for alleged unpaid association dues and assessments amounting to
₱145,567.42.
 Defense of Respondent: Claiming that he had been religiously
paying his dues shown by the fact that he was previously elected
president and director of petitioner.
 Petitioners Argument: Claimed that Cullen’s obligation was a
carry-over of that of MLHI.
 Consequence: respondent was prevented from exercising his right
to vote and be voted for during the 2002 election of petitioner’s
Board of Directors.
 Cullen thus clarified from MLHI the veracity of petitioner’s claim,

but MLHI allegedly claimed that the same had already been settled.
This prompted Cullen to demand from petitioner an explanation why
he was considered a delinquent payer despite the settlement of the
obligation. Petitioner failed to make such explanation. Hence, the
Complaint for Damages filed by respondent against petitioner and
MLHI.
 Petitioner and MLHI filed their separate motions to dismiss the
complaint on the ground of lack of jurisdiction.
 MLHI Contentions: MLHI claims that it is the Housing and Land Use
Regulatory Board (HLURB) which is vested with the exclusive
jurisdiction to hear and decide the case.
 RTC DECISION: The trial court agreed with MLHI that the action for
specific performance filed by respondent clearly falls within the
exclusive jurisdiction of the HLURB.
 CA DECISION: the CA reversed and set aside the trial court’s

decision and remanded the case to the RTC for further proceedings.
 ISSUE: Whether or not the controversy involve intra-corporate

issues as would fall within the jurisdiction of the RTC.
 HELD:
An intra-corporate controversy is one which pertains to any of

the following relationships:
(1) between the corporation, partnership or association and
the public;
the State insofar as its franchise, permit or license to operate
is concerned;
its stockholders, partners, members or officers; and
(4) among the stockholders, partners or associates
themselves.
Admittedly, petitioner is a condominium corporation duly

organized and existing under Philippine laws, charged with the
management of the Medical Plaza Makati. Respondent , on the other
hand, is the registered owner of Unit No. 1201 and is thus a
stockholder/member of the condominium corporation. Clearly, there
is an intra-corporate relationship between the corporation and a
stockholder/member.
Thus, the intra-corporate dispute between petitioner and

respondent is still within the jurisdiction of the RTC sitting as a
special commercial court and not the HLURB.
COURT OF GENERAL JURISDICTION
All cases, the jurisdiction of which is not

specifically provided by law to be within the
jurisdiction of any other court falls within the
jurisdiction of the Regional Trial Court.
ACTIONS INCAPABLE OF PECUNIARY
ESTIMATION
The basic issue in an action incapable of pecuniary

estimation is one other than the recovery of money. In this kind
of action the money claim is merely incidental.
If the action is one primarily for the recovery of money,

the claim is considered capable of pecuniary estimation
ESTIMATION
ILLUSTRATIONS:
1. A complaint for expropriation is incapable of pecuniary

estimation (Barangay San Roque vs. Heirs of Pastor)
2. 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
(Russelvs.Vestil)
ESTIMATION
ILLUSTRATIONS:
3. An action for specific performance is one generally

considered incapable of pecuniary estimation (Russel vs. Vestil,
supra.)
4. The amount of damages that may be claimed in addition

to the prayer for specific performance is not determinative of
jurisdiction. Thus, an action for specific performance and
damages of P200,000.00 is cognizable by the Regional Trial
Court even if the amount of damages sought to be recovered is
within the jurisdiction of the Municipal Trial Court.
ESTIMATION
ILLUSTRATIONS:
5. An action for a writ of injunction is within the

jurisdiction of the Regional Trial Court. It is an action incapable
of pecuniary estimation.
6. An action for the replevin of a motorcycle valued at

P150,000.00 is capable of pecuniary estimation. The basis of
jurisdiction is the value of the personal property sought to be
recovered. The amount of P150,000.00 falls within the
jurisdiction of the MTC.
ESTIMATION
QUESTION:
Plaintiff filed with the RTC an action for Specific

Performance to compel a builder to finish the construction of a
house or to pay him the sum of P250,000. The Defendant Builder
filed a motion to dismiss on the ground that jurisdiction is with
the MTC. The plaintiff opposed the motion to dismiss arguing
that the complaint to compel defendant to finish the
construction is one for specific performance and thus an action
incapable of pecuniary estimation.
Should the RTC grant the motion to dismiss?

ESTIMATION
ANSWER:
YES. The alternative relief for damages made the action

for specific performance capable of pecuniary estimation.
Hence, the jurisdiction lies with the MTC since the amount of
the claim does not exceed P300,000.
ESTIMATION
QUESTION:
Would your answer be the same if what the Plaintiff

filed was an action for specific performance to compel the
builder to finish the construction of the house and to pay
him P250,000?
ESTIMATION
ANSWER:
NO. The action would be for specific performance and

thus incapable of pecuniary estimation. The claim for P250,000
is not equivalent of the action for specific performance since it
was prayed for as additional rather than an alternative relief.
JURISDICTION WHEN ACTING
AS PROBATE COURT
1. Determine whether properties claimed to be part of the

estate should or should not be included in the inventory or list
of properties to be administered subject to a final determination
in a separate action.
2. However, if the interested parties are all heirs, or the

parties consent to the assumption of jurisdiction by the probate
court and third parties are not prejudiced or injured thereby,
the probate court may decide questions on ownership.

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JURISDICTION OF THE

Marie Immaculate L. Clemente

1. Actions in which the subject of litigation is incapable of pecuniary

2. Actions involving title to or possession of real property or any

3. Actions in admiralty and maritime jurisdiction where demand or

4. Matters of probate, testate or intestate, where gross value of estate

5. In all actions involving the contract of marriage and marital

6. Cases not within the exclusive jurisdiction of any court , tribunal,

7. Civil actions and special proceedings falling within exclusive

8. Other cases where the demand, exclusive of interest , damages,

9. Intra-corporate controversies under Sec. 5.2 of the Securities and

• With the SC, SB, and CA

• With the MTC

1. Over all cases decided by the Metropolitan Trial Courts,

2. Decisions of the RTC in the exercise of its appellate

SC may designate certain branches of RTC to try

1. Devices or schemes employed by, or any act of, the board of

2. Controversies arising out of intra-corporate, partnership, or

3. Controversies in the election or appointment of directors, trustees,

4. Derivative suits; and

5. Inspection of corporate book

1. The Relationship Test

1. The Relationship Test

1. Between the corporation, partnership or association and the

2. Between the corporation, partnership or association and the

3. Between the corporation, partnership or association and

4. Among the stockholders, partners or associates themselves .

2. Nature of the Controversy Test

Controversy not only rooted in the existence of intra-

 Respondent Robert H. Cullen purchased from MLHI condominium

 Cullen thus clarified from MLHI the veracity of petitioner’s claim,

 CA DECISION: the CA reversed and set aside the trial court’s

 ISSUE: Whether or not the controversy involve intra-corporate

An intra-corporate controversy is one which pertains to any of

Admittedly, petitioner is a condominium corporation duly

Thus, the intra-corporate dispute between petitioner and

All cases, the jurisdiction of which is not

The basic issue in an action incapable of pecuniary

If the action is one primarily for the recovery of money,

1. A complaint for expropriation is incapable of pecuniary

2. An action to annul a Deed of Declaration of Heirs and for

3. An action for specific performance is one generally

4. The amount of damages that may be claimed in addition

5. An action for a writ of injunction is within the

6. An action for the replevin of a motorcycle valued at

Plaintiff filed with the RTC an action for Specific

Should the RTC grant the motion to dismiss?

YES. The alternative relief for damages made the action

Would your answer be the same if what the Plaintiff

NO. The action would be for specific performance and

1. Determine whether properties claimed to be part of the

2. However, if the interested parties are all heirs, or the

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