Jurisdiction of Philippine trial courts in civil cases, then and now
Before the Regional Trial Court or Second Level Court was established as we know it today, there was the Court of First Instance. Before the Metropolitan Trial Court, Municipal Trial Court, Municipal Circuit Trial Court or First Level Court was the Justice of the Peace. The court system in the Philippines was organized during the American Regime through Act No. 136 (June 11, 1901).
Interestingly, under Act No. 136, the Court of First Instance (CFI) had jurisdiction on civil actions that involve the following: (a) the subject of litigation is incapable of pecuniary estimation; (b) the titles to, possession or interest over real property; (c) the legality of a tax, impost or assessment; or (d) the claim or demand, exclusive of interest, or the value of the property in controversy, amounts to 100 hundred dollars or more (Section 56, Chapter IV).
It also had jurisdiction over maritime and admiralty cases, probate cases, testate or intestate cases, appointments of guardians, trustees or receivers, annulments of marriage, and all other special cases not otherwise provided. It shall also have the power to issue writs of injunction, mandamus, certiorari, prohibition, quo warranto, and habeas corpus in their respective provinces and districts (Section 56, Chapter IV).
After the Philippines was granted independence at the end of WWII, the Philippine legislature passed Republic Act (RA) 296 on 17 June 1948, otherwise known as the “Judiciary Act of 1948.” Under RA 296 the Judges of the CFI were commissioned based on Judicial Districts while the Justices of the Peace were appointed and distributed based on the requirement that each municipality shall have one Justice of the Peace and one auxiliary Justice (Section 68, Chapter V).
The jurisdiction of the CFI in civil cases was generally the same in RA 296 as it was in Act No. 136, except that the demand or the value of the property in controversy amounts to more than two thousand pesos (Section 44 (c), Chapter IV, RA 296). The change in the threshold amount of the claims or demands from dollars to pesos was evidently due to the independence of the Philippines from the United States.
The Justice of the Peace in Act No. 136, a court of lower rank than the CFI, had concurrent jurisdiction with the latter when the demand or value of the property in controversy amounts to 100 dollars or more but less than 300 dollars. It also has jurisdiction on actions for forcible entry or detainer. (Section 68, Chapter V). In RA 296, the jurisdiction of the Justice of the Peace remained; it was only the limit values of the subject matter or the amount of the demand which was stipulated to not exceed two thousand pesos exclusive of interest and cost (Section 88, Chapter V).
RA 296 was amended in 1963 to increase the jurisdictional limit from two thousand pesos to ten thousand pesos (RA 3828). The judiciary was eventually reorganized in 1980 under Batas Pambansa (BP) Blg. 129. The division of courts was changed from Judicial Districts to Judicial Regions. Consequently, the CFI was replaced by the Regional Trial Courts (RTC) while the Justice of the Peace was replaced by the Metropolitan Trial Courts in the metropolitan area, the Municipal Trial Courts in each of the cities or municipalities, and the Municipal Circuit Trial Courts (MTC) in each circuit comprising such cities and/or municipalities (Section 14, Chapter II and Section 25, Chapter III, BP Blg 129).
Under BP Blg. 129, the RTC, previously the CFI, continued to have jurisdiction on admiralty and maritime cases, probate cases, testate and intestate cases but the jurisdictional limit was increased to twenty thousand pesos together with other cases in which the demand exclusive of interest and cost exceeds twenty thousand pesos; the MTCs will take the rest. The RTCs like with the CFIs continued to have jurisdiction over annulment of marriage but its jurisdiction was expanded to include contracts of marriage and marital relations (Section 19, Chapter II, BP 129). BP 129 also transferred cases falling within the exclusive jurisdiction of the Juvenile and Domestic Relations Court and the Court of Agrarian Relations to the RTC’s jurisdiction. The RTC was also given jurisdiction over cases not within the exclusive jurisdiction of any court, tribunal, person or body exercising judicial and quasi-judicial functions (Section 19, Chapter II, BP 129).
In 1994, BP 129 was amended by RA 7691. The amendment introduced for the first time the sharing of jurisdiction of the RTCs and the MTCs in actions that involve titles to, and possession of real property, and interest therein. If the assessed value of the property exceeds twenty thousand pesos, or in Metro Manila, fifty thousand pesos, the RTC will have jurisdiction. In cases wherein the assessed values do not exceed the stated threshold amounts, the action will be filed in their respective MTCs (RA 7691 amending Section 19, Chapter II, BP Blg. 129).
RA 7691 also introduced the sharing of jurisdiction of the RTCs and MTCs in admiralty and maritime cases, probate cases, testate and intestate cases, and all other claims and demands. From a single threshold amount of twenty thousand pesos that distinguished the RTC from the MTC in BP Blg. 129, the amount was increased to one hundred thousand, or two hundred thousand in Metro Manila, to fall within the jurisdiction of the RTC.
The limit amounts were further adjusted in intervals of five years to reach three hundred thousand pesos outside Metro Manila, or four hundred thousand pesos in Metro Manila for the respective RTCs to take cognizance of the cases. Otherwise, the cases will be handled by their respective MTCs. The rest of the jurisdictions conferred by BP 129 to the RTCs and MTCs remained unchanged in RA 7691.
Recently, RA 11576 was passed to further expand the jurisdiction of the RTCs and the MTCs. It must be noted that the amendment no longer distinguishes between cases in Metro Manila or outside of Metro Manila, since the jurisdictional amounts were hugely increased. Hence, civil actions which involve the title to, or possession of, real property, or any interest therein, where the assessed value exceeds four hundred thousand pesos, jurisdiction falls with the RTCs, and those not exceeding the said amount will be taken cognizance by the MTCs (Section 1, RA 11576).
In admiralty and maritime cases, where the demand or claims exceeds two million pesos; matters of probate, both testate and intestate, where the gross value of the estate exceeds two million pesos; and in all other cases in which the demand, exclusive of interest, damages of whatever kind, attorney's fees, litigation expenses and costs or the value of the property in controversy exceeds two million pesos shall be under the jurisdiction of the RTCs (Section 1, RA 11576). Cases of those nature not exceeding the said amount shall be taken by the MTCs. It must be noted that except for the jurisdictional amounts adjusted by RA 11576, the rest of the jurisdiction of the RTCs and MTCs in Batas Pambansa Blg. 129 as amended by Republic Act 7691 remain to be in effect.
Under RA 11576, the authority to adjust the jurisdictional amounts for the First and Second Level Courts was delegated by Congress to the Supreme Court, when necessary, to: (1) reflect the extraordinary supervening inflation or deflation of currency; (2) reflect changes in land valuation; or (3) maintain the proportion of caseload between first and second level courts. This provision is very significant because it gives the Supreme Court the power to adjust the jurisdictional amounts or limits without waiting for an act of Congress (Section 3, RA 11576).
With this recent development, I foresee that the Supreme Court may further adjust the jurisdictional amounts for small claims actions which presently does not exceed four hundred thousand in Metro Manila and three hundred thousand outside of Metro Manila. The said probable adjustment will aid in unclogging the dockets of the MTCs especially for actions purely involving recovery of sums of money arising from contracts of sale, loan, mortgage, services and lease. Congress may even consider creating a small claims court that will handle these types of cases exclusively and expeditiously, without participation of lawyers unless they are the parties.
By: Atty. Tranquil G. S. Salvador III