G.R. No. 152777 - Lacuesta vs. Ateneo de Manila University

On April 27, 1994, petitioner Platinum Tours and Travel Inc. filed a complaint seeking a sum of money with damages against Pan Asiatic Travel Corporation (PATC) and its president, Nelida G. Galvez, for alleged non-payment for airline tickets sold by Platinum.
The case was docketed as Civil Case No. 94-1634, and on October 24, 1994, the Regional Trial Court (RTC) of Makati City, Branch 62, rendered a default judgment in favor of Platinum, awarding actual damages, legal interest, attorney’s fees, and costs.

On February 10, 1995, a writ of execution was issued on the motion of Platinum, resulting in the levy and sale of Manila Polo Club Proprietary Membership Certificate No. 2133, in the name of Nelida G. Galvez, for P479,888.48.
On June 2, 1995, private respondent Jose M. Panlilio filed a motion to intervene in Civil Case No. 94-1634. He claimed that in October 1992, Galvez had executed a chattel mortgage in his favor over her shares in the Manila Polo Club to secure a P1 million loan, and that she had delivered stock certificates valued at P5 million to him.
On June 9, 1995, the trial court denied Panlilio’s motion for intervention, holding that the issues raised were limited to the propriety of the execution and that his intervention would only delay the proceedings.

On January 29, 1996, the trial court declared the execution sale null and void due to irregularities.
On May 3, 1996, Panlilio initiated a collection case against Galvez, seeking a writ of preliminary attachment over the disputed Manila Polo Club shares, and the case was docketed as Civil Case No. 96-365 in Branch 146 of the RTC of Makati City.
Panlilio later attempted to intervene in Civil Case No. 94-1634 by moving for the consolidation of Civil Case No. 96-365 with the earlier case.

On June 13, 1996, Judge Salvador Tensuan of Branch 146 granted the motion for consolidation subject to no objection from Judge Roberto Diokno of Branch 62, who was handling Civil Case No. 94-1634.
Judge Diokno subsequently issued an order on July 23, 1996, allowing the consolidation of the two cases and setting a hearing on Panlilio’s application for a writ of preliminary attachment.
Platinum, as the plaintiff in Civil Case No. 94-1634, moved to reconsider the July 23, 1996 order, but the motion was denied.

On January 31, 1997, Platinum filed a petition for certiorari at the Court of Appeals, challenging the July 23, 1996 order among others.
On January 15, 1998, the Court of Appeals annulled the July 23, 1996 order that allowed the consolidation but left it to Judge Diokno the discretion to either return Civil Case No. 96-365 to Branch 146 or keep it in his docket to decide as a separate case.
Platinum later filed a motion for partial reconsideration requesting that Civil Case No. 96-365 be transferred back to Branch 146 or re-raffled to another branch; this motion was denied on April 2, 1998.

In the instant petition, Platinum argued that following the annulment of the consolidation order, RTC Branch 62 no longer had jurisdiction over Civil Case No. 96-365.
Platinum contended that the annulment extinguished the basis on which Branch 62 acquired jurisdiction over the said case.

The Court explained that jurisdiction is the inherent power to hear and decide a case, which derives from statute and the filing of the complaint, as well as the voluntary appearance of parties.
The decision emphasized that although the consolidation order was annulled, the power and authority of Branch 62 to exercise jurisdiction over Civil Case No. 96-365 remained intact.
The court underscored the distinction between the mere exercise of jurisdiction (e.g., procedural orders) and the inherent power or authority of the court, which is not affected by errors in exercising discretion.

Whether the annulment of Judge Diokno’s July 23, 1996 order allowing the consolidation of Civil Case No. 96-365 with Civil Case No. 94-1634 affects the jurisdiction of RTC Branch 62 over Civil Case No. 96-365.
Whether Platinum’s contention that the annulment of the consolidation order extinguished the basis of jurisdiction of Branch 62 is tenable, given the principles of jurisdiction and its exercise.