The matter of whether the RTC resolves an issue in the exercise of its original jurisdiction [or] of its limited jurisdiction as a special court, is only a matter of procedure and has nothing to do with the question of jurisdiction |
It must be emphasized that "a court's acquisition of jurisdiction over a particular case’s subject matter is different from incidents pertaining to the exercise of jurisdiction.” The Court in Gonzales v. GJH Land, Inc. (Gonzales)¹ differentiated these two matters as follows:
“Jurisdiction over the subject matter of a case is conferred by law, whereas a court’s exercise of jurisdiction, unless provided by the law itself, is governed by the Rules of Court or by the orders issued from time to time by the Court. In Lozada v. Bracewell, it was recently held that the matter of whether the RTC resolves an issue in the exercise of its original jurisdiction or of its limited jurisdiction as a special court is only a matter of procedure and has nothing to do with the question of jurisdiction.” (Emphasis supplied)
The Court then ruled in Gonzales that under Section 5² of Republic Act No. (RA) 8799³, the jurisdiction over cases enumerated in Section 5⁴ of Presidential Decree No. 902-A⁵ is transferred from the Securities and Exchange Commission (SEC) to the RTCs in general and not only in favor of particular RTC branches, i.e., the Special Commercial Courts.⁶
The Court further elucidated in Gonzales that the Court's orders or issuances designating certain or specialized courts, i.e., particular branches, to try and decide cases formerly cognizable by the SEC, among other cases, is to promote expediency and efficiency in the exercise of the RTC's jurisdiction and has nothing to do with the statutory conferment of jurisdiction to all RTCs under RA 8799.
FOOTNOTES
² Section 5 of Republic Act No. 8799 provides in part:
"Section 5. Powers and Functions of the Commission. – 5.1. xxxx
5.2. The Commission's jurisdiction over all cases enumerated under section 5 of Presidential Decree No. 902-A is hereby transferred to the Courts of general jurisdiction or the appropriate Regional Trial Court: Provided, That the Supreme Court in the exercise of its authority may designate the Regional Trial Court branches that shall exercise jurisdiction over the cases. The Commission shall retain jurisdiction over pending cases involving intra-corporate disputes submitted for final resolution which should be resolved within one (1) year from the enactment of this Code. The Commission shall retain jurisdiction over pending suspension of payment/rehabilitation cases filed as of 30 June 2000 until finally disposed.
³ The Securities Regulation Code, approved on July 19, 2000.
⁴Section 5 of Presidential Decree No. 902-A provides:
SECTION 5. In addition to the regulatory and adjudicative functions of the Securities and Exchange Commission over corporations, partnerships and other forms of associations registered with it as expressly granted under existing laws and decrees, it shall have original and exclusive jurisdiction to hear and decide cases involving.
a) Devices or schemes employed by or any acts, of the board of directors, business associates, its officers or partners, amounting to fraud and misrepresentation which may be detrimental to the interest of the public and/or of the stockholder, partners, members of associations or organizations registered with the Commission;
b) Controversies arising out of intra-corporate or partnership relations, between and among stockholders, members, or associates; between any or all of them and the corporation, partnership or association of which they are stockholders, members or associates, respectively; and between such corporation, partnership or association and the state insofar as it concerns their individual franchise or right to exist as such entity;
c) Controversies in the election or appointments of directors, trustees, officers or managers of such corporations, partnerships or associations.
⁵ Entitled, "Reorganization of the Securities and Exchange Commission with Additional Powers and Placing the said Agency under the Administrative Supervision of the Office of the President," approved on March 11, 1976.
⁶As discussed in Concorde Condominium, Inc. v Baculio, supra note 60.
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