Parcon v. Court of Appeals
REITERATIONFacts
1. The Antecedents: The petitioner, Manuel P. Parcon, initiated a legal action seeking to annul a decision previously rendered by the Court of First Instance (CFI) of Manila, Branch XXX, in Civil Case No. 116500. This original decision, dated October 28, 1980, involved Producers Bank of the Philippines, the City Sheriff of Manila, and the Branch Sheriff of the CFI of Manila, Branch XXX, as parties or entities involved in its execution. 2. Procedural History: The petitioner filed his initial complaint for annulment with the Regional Trial Court (RTC) of Iloilo, Branch XXXI, on November 9, 1982. Subsequently, on September 11, 1984, an amended complaint was filed, adding Jessie R. Billena and Alfredo T. Javellana as additional defendants. The RTC of Iloilo dismissed the amended complaint against the intestate estate of Federico Salvador and Gregorio Hechanova due to ongoing administration proceedings. Later, on March 2, 1987, the private respondents moved to dismiss the case, arguing that the RTC of Iloilo lacked jurisdiction following the effectivity of Batas Pambansa Bilang 129. The RTC denied this motion. The Court of Appeals, upon appeal, reversed the RTC's order, declaring the RTC's dismissal order void and ruling that the case should be dismissed for lack of jurisdiction, with the petitioner advised to file in the proper tribunal. 3. The Petition: The petitioner seeks review of the Court of Appeals' decision through a petition for certiorari. The core of the petitioner's argument, as presented to the Supreme Court, hinges on whether the RTC of Iloilo retained jurisdiction over the annulment action after the filing of an amended complaint, particularly in light of Batas Pambansa Bilang 129, which transferred exclusive original jurisdiction over annulment of RTC judgments to the Court of Appeals. The petitioner contends that the RTC should have continued to exercise jurisdiction, while the Court of Appeals found that the amended complaint, filed after Batas Pambansa Bilang 129 took effect, placed the case under its exclusive original jurisdiction.
Issue(s)
Whether the RTC of Iloilo could continue to exercise jurisdiction over an action for the annulment of a decision of the then CFI (now RTC) of Manila after the complaint was amended when Batas Pambansa Bilang 129 was already in effect; and whether the filing of the amended complaint after BP 129 took effect impacted the court's jurisdiction. Whether the RTC of Iloilo had jurisdiction over the amended complaint for annulment of judgment, considering the exclusive original jurisdiction of the Court of Appeals under Section 9(2) of BP 129.
Ruling
The petition is denied, and the decision of the Court of Appeals is affirmed. The RTC of Iloilo cannot continue exercising jurisdiction over Civil Case No. 14708.
Ratio Decidendi
On the issue of jurisdiction over the amended complaint: The Court affirmed the ruling of the Court of Appeals that the RTC of Iloilo no longer had jurisdiction over the case. The Court emphasized that while the original complaint was filed before the enactment of Batas Pambansa Bilang 129 (BP 129), the amended complaint was filed after the law took effect. According to established jurisprudence, when a pleading is amended to introduce a new cause of action or include additional defendants, the original pleading is deemed abandoned, and the case proceeds based solely on the amended complaint. Therefore, the amended complaint, filed after BP 129 became effective, brought the case under the exclusive original jurisdiction of the Court of Appeals, as provided by Section 9(2) of BP 129. This section explicitly grants the Court of Appeals exclusive original jurisdiction over actions for annulment of judgments of Regional Trial Courts. The principle of exclusive jurisdiction precludes the idea of co-existence, meaning that once jurisdiction is vested in one court to the exclusion of others, the latter cannot exercise it. The RTC of Iloilo, therefore, could not validly continue hearing the case after the amendment, as jurisdiction had shifted to the Court of Appeals.
Main Doctrine
An amended complaint that introduces new causes of action or impleads additional defendants, filed after the effectivity of Batas Pambansa Bilang 129, is deemed to stand on the amended complaint alone, placing the case under the exclusive original jurisdiction of the Court of Appeals for actions for annulment of judgments of Regional Trial Courts.