Crespo vs.
Mogul
Facts: An Information for estafa was filed against Mario
Crespo. When the case was set for arraignment, the
accused filed a motion to defer arraignment on the
ground that there was a pending petition for review filed
with the Secretary of Justice for the filing of the
information. The presiding judge, Leodegario Mogul
denied the motion but the arraignment was deferred to
afford time for petitioner to elevate the matter to the
appellate court. Crespo then filed a petition for certiorari
and prohibition with a writ of injunction in the CA to
restrain respondent judge from proceeding with the
arraignment of the accused. The Solicitor General
recommended that the petition be given due course and
the CA granted the same.
Meanwhile, Undersecretary of Justice Catalino Macaraig
reversed the resolution of the Office of the Provincial
Fiscal and directed the fiscal to move for immediate
dismissal of the information filed against Crespo. A
motion to dismiss for insufficiency of evidence was filed
by the Provincial Fiscal with the RTC, but the respondent
judge denied the same and set the date and time for the
arraignment. Crespo then filed in the CA a petition for
certiorari and mandamus with TRO to restrain Mogul from
enforcing his judgment, which was again issued by the
CA. Later on, the CA rendered a decision and dismissed
the petition of Crespo and lifted the TRO. Hence this
present petition.
Issue: W/n the DOJ erred in issuing the resolution for lack
of jurisdiction
Ruling: The rule therefore in this jurisdiction is that once a
complaint or information is led in Court any disposition of
the case as its dismissal or the conviction or acquittal of
the accused rests in the sound discretion of the Court.
Although the scal retains the direction and control of the
prosecution of criminal cases even while the case is
already in Court he cannot impose his opinion on the trial
court. The Court is the best and sole judge on what to do
with the case before it. The determination of the case is
within its exclusive jurisdiction and competence. A motion
to dismiss the case led by the fiscal should be addressed
to the Court who has the option to grant or deny the
same. It does not matter if this is done before or after the
arraignment of the accused or that the motion was led
after a reinvestigation or upon instructions of the
Secretary of Justice who reviewed the records of the
investigation. In order therefor to avoid such a situation
whereby the opinion of the Secretary of Justice who
reviewed the action of the scal may be disregarded by
the trial court, the Secretary of Justice should, as far as
practicable, refrain from entertaining a petition for review
or appeal from the action of the scal, when the complaint
or information has already been led in Court. The matter
should be left entirely for the determination of the Court.
 LPB vs. Corazon Villegas
Facts: Petitioner Land Bank of the Philippines (Land
Bank) filed cases for determination of just compensation
against respondent Corazon M. Villegas in Civil Case
2007-14174 and respondent heirs of Catalino V. Noel
and Procula P. Sy in Civil Case 2007-14193 before the
RTC of Dumaguete City, Branch 32, sitting as a Special
Agrarian Court for the province of Negros Oriental.
Respondent Villegas' property was in Hibaiyo,
Guihulngan City, Negros Oriental, while respondent heirs'
land was in Nangca, Bayawan City, Negros Oriental.
These lands happened to be outside the regular territorial
jurisdiction of RTC Branch 32 of Dumaguete City.
On September 13, 2007 RTC, Branch 32 dismissed Civil
Case 2007-14174 for lack of jurisdiction.[2] It ruled that,
although it had been designated Special Agrarian Court
for Negros Oriental, the designation did not expand its
territorial jurisdiction to hear agrarian cases under the
territorial jurisdiction of the RTC, Branch 64 of
Guihulngan City where respondent Villegas' property can
be found.
On November 16, 2007 RTC, Branch 32 also dismissed
Civil Case 2007-14193 for lack of jurisdiction. It pointed
out that RTC, Branch 63 of Bayawan City had jurisdiction
over the case since respondent heirs' property was within
the latter court's territorial jurisdiction.
Petitioner Land Bank moved for the reconsideration of
the dismissal of the two cases but RTC, Branch 32
denied both motions.[3] Aggrieved, Land Bank directly
filed this petitions for certiorari[4] before this Court, raising
a purely question of law.
Issue: W/n an RTC, acting as Special Agrarian Court,
has jurisdiction over just compensation cases involving
agricultural lands located outside its regular jurisdiction
but within the province where it is designated as an
agrarian court under the Comprehensive Agrarian
Reform Law of 1998.
Ruling:
Section 57. Special Jurisdiction. — The Special
Agrarian Courts shall have original and exclusive
jurisdiction over all petitions for the determination of just
compensation to landowners, and the prosecution of all
criminal offenses under this Act. The Rules of Court shall
apply to all proceedings before the Special Agrarian
Courts, unless modified by this Act.
The Special Agrarian Courts shall decide all appropriate
cases under their special jurisdiction within thirty (30)
days from submission of the case for decision.
The law is clear. A branch of an RTC designated as a
Special Agrarian Court for a province has the original and
exclusive jurisdiction over all petitions all petitions for the
determination of just compensation in that province. In
Republic vs CA, the Supreme Court ruled that Special
Agrarian Courts have original and exclusive jurisdiction
over two categories of cases: (1) all petitions all petitions
for the determination of just compensation to landowners,
and (2) the prosecution of all criminal offenses under R.A.
6657. By "special" jurisdiction, Special Agrarian Courts
exercise power in addition to or over and above the
ordinary jurisdiction of the RTC, such as taking
cognizance of suits involving agricultural lands located
outside their regular territorial jurisdiction, so long as they
are within the province where they sit as Special Agrarian
Courts. R.A. 6657 requires the designation by the
Supreme Court before an RTC Branch can function as a
Special Agrarian Court. The Supreme Court has not
designated the single s ala courts of RTC, Branch 64 of
Guihulngan City and RTC, Branch 63 of Bayawan City as
Special Agrarian Courts. Consequently, they cannot hear
just compensation cases just because the lands subject
of such cases happen to be within their territorial
jurisdiction. Since RTC, Branch 32 of Dumaguete City is
the designated Special Agrarian Court for the province of
Negros Oriental, it has jurisdiction over all all cases for
determination of just compensation involving agricultural
lands within that province, regardless of whether or not
those properties are outside its regular territorial
jurisdiction.
 Tijam vs. Sibonghanoy
Facts: Spouses Serafin and Felicitas commenced a civil
case against spouses Sibonghanoy to recover from them
a sum of P1, 908.00 with legal interest. A writ of
attachment was issued by the court against the
defendants’ properties but the same was soon dissolved.
After trial, the court rendered judgment in favor of the
plaintiffs and after the same hadbecome final and
executor, the court issued a writ of execution against the
defendants. Thewrit being unsatisfied, the plaintiffs
moved for the issuance of the writ of execution against
Surety’s bond. Subsequently, the Surety moved to quash
the writ on the ground that the same was issued without
summary hearing. This was denied by the RTC. The
Surety appealed in the CA, which was denied. This time,
the surety just asked for an extension in order for them to
file the motion for reconsideration. But instead of filing for
a motion for reconsideration, it filed a motion to dismiss
saying that by virtue of R.A. 296 which is the Judiciary
Reorganization Act of 1948, section 88 of which placed
within the exclusive original jurisdiction of inferior courts
all civil action where the value of the subject matter
does not exceed P2,000.00. The Court of First Instance
therefore has no jurisdiction over the case. Thequestion
of jurisdiction was filed by the Surety only 15 years from
the time the action was commenced in the Court of
First Instance.
Issue: W/n the case should be dismissed for lack of
jurisdiction
Ruling: It is undisputed fact that the action commenced
by appellees in the Court of First Instance of Cebu
against the Sibonghanoy spouses was for the recovery of
the sum of P1,908.00 only — an amount within the
original exclusive jurisdiction of inferior courts in
accordance with the provisions of the Judiciary Act of
1948 which had taken effect about a month prior to the
date when the action was commenced. True also is the
rule that jurisdiction over the subject matter is conferred
upon the courts exclusively by law, and as the lack of it
affects the very authority of the court to take cognizance
of the case, the objection may be raised at any stage of
the proceedings. However, considering the facts and
circumstances of the present case, We are of the opinion
that the Surety is now barred by laches from invoking this
plea at this late hour for the purpose of annulling
everything done heretofore in the case with its active
participation.