Posted by: Petros Absalon C. Bojo, 26 July 2018
FACTS:
Maxima de Jesus, along with petitioners and six others, are co-owners of six (6) parcels of land in Manila. She was the Administrator as well as the co-owners attorney-in-fact. Her stipulated compensation is 10% of the rentals.
Lessee of the property is Shell Company of the Philippines, Ltd. This lease was renewed, where under, through the efforts of Maxima de Jesus, the monthly rentals were increased from P850.00 to P3,500.00 during the first ten (10) years and to P4,000.00 for the subsequent five (5) years. Shell pays the rentals by issuing a check in the name of Maxima de Jesus who, in turn, distributes the shares of her co-owners.
Petitioners, wanted to deprive Respondent de Jesus of her 10% compensation, and to this end in sight they instructed Shell not to pay their share through her and instead pay it directly to them.
Upon the filing of the complaint Respondent Judge Garcia issued an ex-parte writ of preliminary injunction.
The here in Petitioners brought directly to the Court the case on question of jurisdiction.
ISSUE:
Whether or not the Trial Court had jurisdiction over the case.
HELD:
Jurisdiction over the subject matter is conferred only by the Constitution or law. It cannot be fixed by the will of the parties; it cannot be acquired through, or waived, enlarged or diminished by, any act or omission of the parties. Neither is it conferred by acquiescence of the court. Constitutionally viewed, apportionment of jurisdiction is vested in Congress. Congress may not delegate that power. We may not even look to the Rules of Court in search of jurisdiction jurisdictional boundaries. For indeed, the constitutional authority of the Supreme Court on this point is circumscribed in the zone properly denominated as the promulgation of "rules concerning pleading, practice, and procedure in all courts and the admission to the practice of law"; and, consequently to determine the "means, ways or manner in which said jurisdiction, as fixed by the Constitution and acts of Congress, shall be exercised". Rules of Court must yield to substantive laws9 of which jurisdiction is a segment. A mistake in statutory jurisdiction may not be corrected by executive fiat, "but by legislation".
Well may we profit from the wise pronouncement in Manila Railroad Co. vs. Attorney-General, supra, at pages 529-530, thus: "Certain statutes confer jurisdiction, power, or authority. Others provide for the procedure by which that power or authority is projected into judgment. The one class deals with the powers of the court in the real and substantive sense; the other with the procedure by which such powers are put into action. The one is the thing itself ; the other is the vehicle by which the thing is transferred from the court to the parties. The whole purpose and object of procedure is to make the powers of the court fully and completely available for justice. ... The purpose of such a procedure is not to restrict the jurisdiction of the court over the subject matter, but to give it effective facility in righteous action. ..."
A rule, the validity of which is recognized, is that jurisdiction of an inferior court will not be presumed; "it must appear clearly from statute or it will not be held to exist."11 Such jurisdiction cannot be broadened upon "doubtful inferences" drawn from statutes. Absent a statutory grant, neither convenience nor assumed justice or propriety of the exercise thereof in a particular class of cases "can justify the assumption of jurisdiction" by said courts.
The City Court has no jurisdiction of a suit for specific performance of a contract, although the damages alleged for its breach, if permitted, are within the amount of which that court has jurisdiction.
FACTS:
Maxima de Jesus, along with petitioners and six others, are co-owners of six (6) parcels of land in Manila. She was the Administrator as well as the co-owners attorney-in-fact. Her stipulated compensation is 10% of the rentals.
Lessee of the property is Shell Company of the Philippines, Ltd. This lease was renewed, where under, through the efforts of Maxima de Jesus, the monthly rentals were increased from P850.00 to P3,500.00 during the first ten (10) years and to P4,000.00 for the subsequent five (5) years. Shell pays the rentals by issuing a check in the name of Maxima de Jesus who, in turn, distributes the shares of her co-owners.
Petitioners, wanted to deprive Respondent de Jesus of her 10% compensation, and to this end in sight they instructed Shell not to pay their share through her and instead pay it directly to them.
Upon the filing of the complaint Respondent Judge Garcia issued an ex-parte writ of preliminary injunction.
The here in Petitioners brought directly to the Court the case on question of jurisdiction.
ISSUE:
Whether or not the Trial Court had jurisdiction over the case.
HELD:
Jurisdiction over the subject matter is conferred only by the Constitution or law. It cannot be fixed by the will of the parties; it cannot be acquired through, or waived, enlarged or diminished by, any act or omission of the parties. Neither is it conferred by acquiescence of the court. Constitutionally viewed, apportionment of jurisdiction is vested in Congress. Congress may not delegate that power. We may not even look to the Rules of Court in search of jurisdiction jurisdictional boundaries. For indeed, the constitutional authority of the Supreme Court on this point is circumscribed in the zone properly denominated as the promulgation of "rules concerning pleading, practice, and procedure in all courts and the admission to the practice of law"; and, consequently to determine the "means, ways or manner in which said jurisdiction, as fixed by the Constitution and acts of Congress, shall be exercised". Rules of Court must yield to substantive laws9 of which jurisdiction is a segment. A mistake in statutory jurisdiction may not be corrected by executive fiat, "but by legislation".
Well may we profit from the wise pronouncement in Manila Railroad Co. vs. Attorney-General, supra, at pages 529-530, thus: "Certain statutes confer jurisdiction, power, or authority. Others provide for the procedure by which that power or authority is projected into judgment. The one class deals with the powers of the court in the real and substantive sense; the other with the procedure by which such powers are put into action. The one is the thing itself ; the other is the vehicle by which the thing is transferred from the court to the parties. The whole purpose and object of procedure is to make the powers of the court fully and completely available for justice. ... The purpose of such a procedure is not to restrict the jurisdiction of the court over the subject matter, but to give it effective facility in righteous action. ..."
A rule, the validity of which is recognized, is that jurisdiction of an inferior court will not be presumed; "it must appear clearly from statute or it will not be held to exist."11 Such jurisdiction cannot be broadened upon "doubtful inferences" drawn from statutes. Absent a statutory grant, neither convenience nor assumed justice or propriety of the exercise thereof in a particular class of cases "can justify the assumption of jurisdiction" by said courts.
The City Court has no jurisdiction of a suit for specific performance of a contract, although the damages alleged for its breach, if permitted, are within the amount of which that court has jurisdiction.
