Equity jurisdiction versus appellate jurisdiction of the RTC
The appellate jurisdiction of courts is conferred by law. The appellate court acquires jurisdiction over the subject matter and parties when an appeal is perfected.42
On the other hand, equity jurisdiction aims to provide complete justice in cases where a court of law is unable to adapt its judgments to the special circumstances of a case because of a resulting legal inflexibility when the law is applied to a given situation. The purpose of the exercise of equity jurisdiction, among others, is to prevent unjust enrichment and to ensure restitution.43
The RTC orders which allowed the withdrawal of the deposited funds for the use and occupation of the subject units were issued pursuant to the RTC’s equity jurisdiction, as the CA held in the petition docketed as CA-G.R. SP No. 81277.
The RTC’s equity jurisdiction is separate and distinct from its appellate jurisdiction on the ejectment case. The RTC could not have issued its orders in the exercise of its appellate jurisdiction since there was nothing more to execute on the dismissed ejectment case. As the RTC orders explained, the dismissal of the ejectment case effectively and completely blotted out and cancelled the complaint. Hence, the RTC orders were clearly issued in the exercise of the RTC’s equity jurisdiction, not on the basis of its appellate jurisdiction.
This Court takes judicial notice44 that the validity of the RTC Orders has been upheld in a separate petition before this Court, under G.R. SP No. 171429 entitled Antonio Dela Cruz v. Regulus Development, Inc.
The levy of the respondent’s property was made pursuant to the RTC orders issued in the exercise of its equity jurisdiction, independent of the ejectment case originally filed with the MTC. (Regulus Development vs. dela Cruz, G.R. No. 198172, 25 Jan. 2016)
