Case Digest (G.R. No. 117383)
Facts:
Rizal Commercial Banking Corporation (RCBC) v. Hon. Lucia V. Isnani, Hon. Felicidad Y. Navarro-Quiambao, and Lolita Encelan, G.R. No. 117383, March 06, 1995, Supreme Court Third Division, Vitug, J., writing for the Court.
On 27 April 1994, private respondent Lolita Encelan filed a complaint in the Makati Regional Trial Court (RTC) seeking recovery of actual damages in the amount of US$5,000.00 (approximately P137,675.00). RCBC (petitioner) moved to dismiss for lack of jurisdiction, contending that the complaint was cognizable by the Metropolitan Trial Court (MTC) in Metro Manila because the principal demand did not exceed the P200,000.00 threshold established by the new statutory scheme.
Instead of granting the motion to dismiss, RTC Judge Lucia V. Isnani transferred the entire records of the case to the MTC on 08 July 1994. The case was assigned to MTC Judge Felicidad Y. Navarro-Quiambao, who denied petitioner’s motion for reconsideration on 16 September 1994. RCBC then elevated the matter to the Supreme Court.
The Court noted that it had earlier dismissed this petition for procedural noncompliance with Revised Circular No. 1-88 (requirement (4) — verified statement of material dates) but reconsidered and dispensed with that requirement to address the substantive question promptly. The Court examined Republic Act No. 7691 (which amended provisions on the jurisdiction of municipal and metropolitan trial courts), particularly Section 3 (amending Section 33) and Section 7, and observed that R.A. No. 7691 took effect on 15 April 1994 (fifteen days after its publication on 30 March 1994). The statute raised the Metro Manila jurisdictional ceiling to P200,000.00 (exclusive of interest, certain damages, attorneys’ fees and costs) and contained transitional rules about cases pending at the time of effectivity.
Applying R.A. No. 7691 to the instant complaint filed after the statute’s effectivity, the Court concluded the principal demand was within the exclusive jurisdiction of th...(Subscriber-Only)
Issues:
- Did the Makati Regional Trial Court have jurisdiction over the complaint filed on April 27, 1994, or was the action within the exclusive original jurisdiction of the Metropolitan Trial Court under R.A. No. 7691?
- If the MTC had exclusive jurisdiction, was the proper remedy for the RTC to transfer the case to the MTC or to dismiss the compla...(Subscriber-Only)
Ruling:
- (Subscriber-Only)
Ratio:
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Doctrine:
- (Subscriber-Only)