G.R. No. L-18783 - Baje vs. Court of Appeals

On November 9, 1982, the petitioner filed a complaint with the RTC of Iloilo, Branch XXXI, docketed as Civil Case No. 14708.
The complaint sought the annulment of a decision dated October 28, 1980, rendered by the then CFI of Manila, Branch XXX in Civil Case No. 116500.
The original defendants included Producers Bank of the Philippines, the City Sheriff of Manila, and the Branch Sheriff of the CFI of Manila, Branch XXX.

On September 11, 1984, the petitioner filed an amended complaint.
The amendment impleaded Jessie R. Billena and Alfredo T. Javellana as private respondents.
Additionally, the amended complaint brought in the Intestate Estate of Federico Salvador and Gregorio Hechanova as defendants.
The RTC of Iloilo subsequently dismissed the portion of the amended complaint involving the said estate, due to the commencement of administration proceedings over it.

On March 2, 1987, the newly impleaded private respondents filed a motion to dismiss the case.
The basis for the dismissal challenged the RTC of Iloilo’s jurisdiction, asserting that the amendment was filed after the effectivity of Batas Pambansa Bilang 129, which was already in force as of January 18, 1983.
Batas Pambansa Bilang 129 vested exclusive original jurisdiction over actions for annulment of Regional Trial Court judgments to the Court of Appeals.
Despite the motion to dismiss, the RTC of Iloilo denied the petition for dismissal, leading to further appeal.

The annulment order by the respondent judge (from December 28, 1987) as null and void.
That Civil Case No. 14708 be dismissed for lack of jurisdiction.
The petitioner be advised to file the complaint before the appropriate tribunal in line with Batas Pambansa Bilang 129.

This decision became the basis of the instant petition challenging the jurisdictional issue.

Batas Pambansa Bilang 129, effective January 18, 1983, diverted the jurisdiction to the Court of Appeals for cases involving the annulment of RTC decisions.
Sections 9(2) and 44 of the law were cited to underscore:

The exclusive nature of the Court of Appeals’ jurisdiction over such cases.
The immediate effectivity and reorganization of the courts under the new statutory framework.

Jurisprudence (e.g., Insular Veneer, Inc. v. Plan) reinforced that an amendment introducing new causes of action or additional defendants effectively abandons the original pleading, causing the case to stand on the amended complaint.

Whether the RTC of Iloilo could continue to exercise jurisdiction over an action for the annulment of an RTC (formerly CFI) decision after the petitioner amended the complaint post-effectivity of Batas Pambansa Bilang 129.
Whether the amendment which introduced additional defendants and essentially a new cause of action reclassified the case under the exclusive jurisdiction of the Court of Appeals, as mandated by the law.
The proper interpretation and application of the transitional provisions enacted by Batas Pambansa Bilang 129 in determining the proper venue for the filed complaint.