G.R. No. 219708 - Tourism Infrastructure and Enterprise Zone Authority vs. Global-V Builders Co.

The petitioners, Catalino Sevilla et al., sought the recall of a case that had been transferred from the Supreme Court to the Court of Appeals.
The petition asserted that the case was erroneously certified and transferred by the clerk of the Supreme Court.

Commonwealth Act No. 3 (effective February 1, 1936) amended the Revised Administrative Code by:

Under the Act, the appellate jurisdiction of the Supreme Court was limited to specific categories, including:

Cases questioning the constitutionality or validity of treaties, laws, ordinances, or executive orders;
Cases involving the legality of taxes or penalties related thereto;
Cases questioning the jurisdiction of inferior courts;
Criminal cases with penalties of death or life imprisonment;
Civil cases with controversies exceeding twenty-five thousand pesos or involving contested real estate titles above that value; and
Other cases involving only errors or questions of law.

Conversely, the Court of Appeals was given exclusive appellate jurisdiction over all cases and proceedings not enumerated under the Supreme Court’s limited jurisdiction.

Commonwealth Act No. 3 provided that once the Court of Appeals was organized, all pending cases in the Supreme Court that fell under its newly allocated jurisdiction—if not already heard and submitted for decision—shall be certified by the clerk of the Supreme Court to the clerk of the Court of Appeals.
Following the organization of the Court of Appeals, the clerk of the Supreme Court duly certified to the Court of Appeals all such pending cases, except those already heard or submitted on argument.

Commonwealth Act No. 259, approved on April 7, 1938, effected a new apportionment of appellate jurisdiction between the Supreme Court and the Court of Appeals.
Under this new apportionment, all civil cases—except those falling under specific exceptions—in which the value in controversy does not exceed fifty thousand pesos (exclusive of interests and costs) or in which the title or possession of real estate not exceeding the same value is involved become exclusively appealable to the Court of Appeals.
The instant case involved the title to a piece of land whose value was significantly below fifty thousand pesos, thereby placing it squarely under the exclusive appellate jurisdiction of the Court of Appeals.
Additionally, the case raised questions of fact, and neither the jurisdiction of the lower court nor any constitutional question was triggered under the statutory provisions.

Petitioners contended that the certification of the case as performed by the clerk of the Supreme Court was erroneous under the transitory provision of section 145‑0 of Commonwealth Act No. 3.
They argued that this provision should not continue to be invoked after the approval of Commonwealth Act No. 259 and that the case should be recalled to the Supreme Court.
The petitioners maintained that their appeal, involving issues of fact, should not have been automatically transferred to the Court of Appeals under the revised statutory scheme.

Whether the certification by the clerk of the Supreme Court under section 145‑0 of Commonwealth Act No. 3, which was intended as a transitory measure, confers a continuing power to remove pending cases from the Supreme Court’s docket even after the enactment of Commonwealth Act No. 259.
Whether statutory changes regarding appellate jurisdiction apply to pending cases in a manner that mandates their transfer to the Court of Appeals, thereby barring the recall of the case to the Supreme Court.
Whether the petitioners’ argument—that the case should not have been certified to the Court of Appeals—is tenable in light of the legislative intent and the remedial nature of the relevant statutory provisions.