Platinum Tours and Travel, Inc. v. Panlilio
REITERATIONFacts
The Antecedents: Petitioner Platinum Tours and Travel, Inc. (Platinum) filed a complaint for a sum of money with damages against Pan Asiatic Travel Corporation (PATC) and its president, Nelida G. Galvez, for unpaid airline tickets, docketed as Civil Case No. 94-1634. The Regional Trial Court (RTC) of Makati City, Branch 62, rendered a default judgment in favor of Platinum. A writ of execution was issued, and a membership certificate of Galvez in the Manila Polo Club was levied and sold. Private respondent Jose M. Panlilio filed a motion to intervene, claiming a prior chattel mortgage over Galvez's shares in the Manila Polo Club to secure a loan. The trial court denied the motion for intervention, stating that a decision had already been rendered and the intervenor's rights could be protected in a separate action. Subsequently, the execution sale was declared null and void due to irregularities. Panlilio then filed a collection case against Galvez with an application for a writ of preliminary attachment over the disputed shares, docketed as Civil Case No. 96-365, which was raffled to RTC Makati City, Branch 146. Panlilio again sought to intervene in Civil Case No. 94-1634 by filing a motion to consolidate both cases. The RTC of Branch 146 granted the consolidation on condition that the RTC of Branch 62 would not object. Judge Diokno of Branch 62 issued an order allowing the consolidation, which Platinum moved to reconsider. The motion for reconsideration was denied. Procedural History: Platinum filed a petition for certiorari with the Court of Appeals (CA) assailing the order allowing consolidation. The CA annulled the assailed order but left it to Judge Diokno to decide whether to return Civil Case No. 96-365 to Branch 146 or keep it as a separate case in his docket. Platinum moved for partial reconsideration, praying that Civil Case No. 96-365 be returned to Branch 146 or re-raffled, but the CA denied the motion. The Petition: Platinum filed a petition for review on certiorari with the Supreme Court, arguing that the RTC, Branch 62, had no jurisdiction to try Civil Case No. 96-365 after its order allowing consolidation was annulled, thereby extinguishing the basis for acquiring jurisdiction.
Issue(s)
Whether the RTC, Branch 62, retained jurisdiction over Civil Case No. 96-365 after its order allowing the consolidation of Civil Case No. 96-365 with Civil Case No. 94-1634 was annulled and set aside. Whether the Court of Appeals committed reversible error in leaving to the discretion of the respondent judge whether to return Civil Case No. 96-365 to Branch 146 or to decide it as a separate case.
Ruling
The petition is denied. The assailed decision of the Court of Appeals is affirmed. The RTC of Makati, Branch 62, may proceed with Civil Case No. 96-365, and if it decides to retain the case, it is directed to resolve the same with dispatch.
Ratio Decidendi
On the issue of jurisdiction over Civil Case No. 96-365: The Supreme Court held that jurisdiction is the power and authority of the court to hear, try, and decide a case, conferred by law and determined by the allegations of the complaint. It is not dependent on the regularity of the exercise of that power or the correctness of its decisions. In this case, Civil Case No. 96-365, a collection case filed by Panlilio against Galvez, clearly falls within the jurisdiction of the RTC of Makati, Branch 62, based on the nature of the action and the subject matter. The fact that the Court of Appeals annulled the order of consolidation did not affect the jurisdiction of the court that issued the order. Jurisdiction refers to the authority to decide a case, not the orders or decisions rendered therein. Any error in the exercise of jurisdiction is merely an error of judgment, which does not divest the court of its authority to decide the case. Therefore, the annulment of the consolidation order did not extinguish the RTC Branch 62's jurisdiction over Civil Case No. 96-365. On the Court of Appeals' discretion: The Supreme Court found no reversible error on the part of the Court of Appeals when it left to Judge Diokno of Branch 62 the discretion on whether to return Civil Case No. 96-365 to Branch 146 or to decide the same as a separate case in his own sala. The Court noted that the petition was premature and speculative, as Platinum could have waited for Judge Diokno's decision on the matter. The Court also observed that Platinum's "unfounded fear" that Civil Case No. 96-365 would unduly delay the resolution of Civil Case No. 94-1634 led to premature action, wasting the time of the parties and the Court. The Court reiterated that nothing legally prevents the RTC of Makati, Branch 62, from proceeding with Civil Case No. 96-365 and directed that it be resolved with dispatch should the judge decide to retain it.
Main Doctrine
The annulment of an order allowing the consolidation of two cases does not divest the court that issued the order of its jurisdiction over one of the cases, as jurisdiction is conferred by law and determined by the allegations of the complaint, not by the regularity or correctness of the court's exercise of power.