Facts:
On June 8, 2007, petitioner
Eriberto P. Crisostomo sought review on certiorari under
Rule 45 of a December 2, 2005 Decision of the Regional Trial Court (RTC) of San Jose City, Branch 38, which had dismissed his special civil action challenging the denial by the Municipal Trial Court in Cities (MTCC), Branch 1, San Jose City, of his motion to dismiss in Civil Case No. 3706. The controversy stemmed from respondent
Arnie R. De Guzman’s claim for
collection of a sum of money based on the alleged sale of bakery products. Petitioner allegedly purchased bakery products worth
P1,262,121.00 and left an unpaid balance of
P277,121.00. Petitioner promised to pay in June 2003 but failed to do so despite several demands; consequently, on
March 24, 2004, respondent filed the complaint before the
MTCC, San Jose City, docketed as
Civil Case No. 3706, and raffled to Branch 1. On
November 8, 2004, petitioner filed a motion to dismiss on the theory that the MTCC had no jurisdiction because, under
Section 5 of BP 129, as amended by
RA 7691, the increased jurisdiction over claims exceeding
P200,000.00 had allegedly taken effect only on
April 12, 2004. Petitioner argued that, while
RA 7691 required adjustments after five years, the Office of the Court Administrator (OCA) had allegedly fixed erroneous effectivity dates through
OCA Circular No. 21-99 (April 15, 1999, for the first adjustment) and
OCA Circular No. 65-2004 (May 13, 2004, for the second adjustment), and that the alleged miscalculation resulted from counting only
360 days per year instead of
365. The MTCC denied the motion to dismiss on
March 7, 2005, reasoning that petitioner effectively assailed the correctness and validity of the OCA circulars and that the MTCC had no authority to alter, modify, or declare Supreme Court administrative circulars invalid; it also noted that the jurisdictional amount for first level courts had already been adjusted by then. Without seeking reconsideration, petitioner proceeded by certiorari and prohibition before the RTC, which on
December 2, 2005 dismissed the petition for lack of grave abuse of discretion. The RTC held that the MTCC merely applied the effectivity dates fixed by the OCA for implementing RA 7691 and acted in accordance with
Section 7 of RA 7691, which directed transfer to first level courts of cases pending before the RTC that had not yet reached the pre-trial stage. Petitioner’s motion for reconsideration was denied, after which he elevated the matter to the Supreme Court under
Rule 45, raising, in substance, whether the second adjustment under RA 7691 took effect only on April 12, 2004, whether the MTCC properly assumed jurisdiction consistent with Section 7, and whether the RTC erred in considering issues raised in the motion for reconsideration. The Supreme Court denied the petition.
Issues:
Whether the MTCC gravely abused its discretion in denying petitioner’s motion to dismiss on the ground that the MTCC lacked jurisdiction because the second adjustment under
Section 5 of RA 7691 allegedly took effect only on
April 12, 2004.
Ruling:
Ratio:
Doctrine: