1.

Facts:

Heirs of Del Rosario vs. Rosario (Jurisdiction of PARAD and DARAB)

Issues: 1. WON PARAD and DARAB have jurisdiction to take cognizance of the petitioners complaint for amendment and partition if the PARAD and the DARAB have no jurisdiction over the complaint for amendment and partition, whether the petitioners are bound by their respective dispositions.

The subject land was owned by Lazaro tenanted by Spouses Del Rosario. Spouses Del Rosario had three children: Monica, Candido and Gil. Petitioners claimed that when Spouses Del Rosario died, only they continued to tenant and actually till the subject land. Monica and Gil agreed that the latter would facilitate the application for an E.P. over the subject land in the name of the former. In exchange, Monica agreed to cede to Gil one-third of the said land. DAR issued to Monica E.P. Despite repeated demands, Monica refused to cede to Gil the one-third portion of the subject land Petitioners filed with PARAD a complaint against Monica for amendment of TCT and partition of the subject land. PARAD rendered decision in favor of the petitioners. (Monica was not the bona fide tenant-farmer of the subject land and that she had continuously failed to cultivate or develop the same.) Monica appealed to DARAB. DARAB reversed decision of PARAD. (Subject land is not part of their inheritance. Tenants are not the owners of the landholding they cultivate. Right to cultivate by Spouses Del Rosario as tenants was passed to Monica as the eldest child. Agreement between Monica and Gil is contrary to law as P.D. No. 27 prohibits the transfer of parcels of land given to qualified farmer-beneficiaries other than by hereditary succession or to the government.) Petitioners filed a petition for review with the CA CA denied petition. (PARAD and the DARAB had no jurisdiction. (There being no agrarian dispute or tenancy relations between the parties. The petitioners are bound by the decision of the DARAB declaring Monica as the bona fide holder since they participated in the proceedings before the PARAD and the DARAB without raising any objection thereto.) Hence, this petition

2.

Held: 1. NO. The Complaint for amendment and partition does not involve any agrarian dispute, nor does it involve any incident arising from the implementation of agrarian laws. The petitioners and Monica have no tenurial, leasehold, or any agrarian relations whatsoever that will bring this controversy within the jurisdiction of the PARAD and the DARAB. Further, the instant case does not involve an incident arising from the implementation of agrarian laws NO. Jurisdiction over the subject matter cannot be acquired through, or waived by, any act or omission of the parties. The active participation of the parties in the proceedings before the DARAB does not vest jurisdiction on the DARAB, as jurisdiction is conferred only by law. The courts or the parties cannot disregard the rule of non-waiver of jurisdiction. Likewise, estoppel does not apply to confer jurisdiction to a tribunal that has none over a cause of action. In a long line of decisions, this Court has consistently held that an order or decision rendered by a tribunal or agency without jurisdiction is a total nullity.

2.

2. Facts:

Spouses Dela Cruz vs. Concepcion

Petitioners entered into a Contract to Sell with respondent involving a house and lot for a consideration of P2,000,000.00. Respondent was able to pay a total of P2,000,000.00. Respondent told petitioners her unpaid obligation which includes interests and penalties was only P200,000.00. Petitioners agreed. The title to the property was transferred to respondent. Petitioners later reminded respondent to pay P209,000.00 w/in 3 months. They claimed that the said amount remained unpaid, despite the transfer of the title to the property to respondent.

Petitioners made further demands stating the supposed correct computation. Despite repeated demands,respondent did not pay. Hence, the Complaint

for Sum of Money With Damages

Respondent claimed that her unpaid obligation to petitioners is only P200,000.00 as earlier confirmed by petitioners and not P487,384.15 as later alleged in thecomplaint. Respondent thus prayed for the dismissal of the complaint Respondent presented receipt as evidence indicating payment of the remaining balance of P200,000.00 to Losloso, petitioners purported representative. Respondent filed a counterclaim for moral damages and attorneys fees RTC rendered decision in favour or respondent. (evidence formally offered by petitioners have not actually been marked as none of the markings were recorded. Thus, it found no basis to grant their claims, especially since the amount claimed in the complaint is different from that testified to.) CA affirmed the decision Petition for certiorari is filed. Facts:

offered as evidence, petitioners did not manifest their objection to the admissibility of said document on the ground that payment was not an issue. Apparently,petitioners only denied receipt of said payment and assailed the authority of Losloso to receive payment. Since there was an implied consent on the part of petitioners to try the issue of payment, even if no motion was filed and no amendment of the pleading has been ordered, RTC cannot be faulted for admitting respondents testimonial and documentary evidence to prove payment. 3. YES. Respondents obligation consists of payment of a sum of money. In order to extinguish said obligation, payment should be made to the proper person as set forth in Article 1240 of the Civil Code, to wit: Article 1240. Payment shall be made to the person in whose favour the obligation has been constituted, or his successor in interest, or any person authorized to receive it.

Issues: 1. 2.

3.Estel vs. Diego (Forcible entry and unlawful detainer cases fall within the exclusive original jurisdiction of lower courts) -

Whether or not evidence of the respondent can be judicially admitted even though it was not raised in the pleadings Whether or not respondents obligation had already been extinguished by payment.

Respondents entered into a contract of sale of a parcel of land with petitioner. Respondents had been in actual, adverse and uninterrupted possession of the subject lot since then petitioner never disturbed respondents Petitioner, together with her two sons and five other persons, uprooted the fence surrounding the disputed lot, entered its premises and then cut and destroyed the trees and plants found therein Respondents prayed for the restoration of their possession and for the issuance of a permanent injunction MTCC decided in favour of respondents RTC affirmed decision of MTCC CA affirmed decision of RTC Petitioner contends that since respondents failed to allege the location of the disputed parcel of land in their complaint, the MTCC did not acquire jurisdiction over the subject matter of the said complaint. Petitioner also avers that the MTCC did not acquire jurisdiction over the case for failure of respondents to specifically allege facts constitutive of forcible entry. Petition for certiorari is filed.

Held: 1. YES. Section 1, Rule 9 of the Rules of Court states that defenses and objections not pleaded either in a motion to dismiss or in the answer are deemed waived. Hence, respondent should have been barred from raising the defense of payment of the unpaid P200,000.00. However, Section 5, Rule 10 of the Rules of Court allows the amendment to conform to or authorize presentation of evidence: When issues not raised by the pleadings are tried with the express or implied consent of the parties, they shall be treated in all respects as if they had been raised in the pleadings. On the other hand, when there is an objection, the evidence may be admitted where its admission will not prejudice him. Thus, while respondent judicially admitted in her Answer that she only paid P2 million and that she still owed petitioners P200,000.00, respondent claimed later and, in fact, submitted an evidence to show that she already paid the whole amount of her unpaid obligation. It is noteworthy that when respondent presented the evidence of payment, petitioners did notobject thereto. When the receipt was formally

Issue: WON the MTCC acquired jurisdiction over the case? Held: Yes. Petitioner did not raise the issue of jurisdiction or venue in her answer filed with the MTCC. In fact, petitioner did not even raise this issue in her appeal filed with the RTC. Thus, she is already estopped from raising the said issue in the CA or before this Court. Estoppel sets in when a party participates in all stages of a case before challenging the jurisdiction of the lower court. Since the Complaint is one for forcible entry, the jurisdiction over the subject matter of the case is, thus, upon the MTCC. Section 33 BP Blg. 129, as amended by Section 3 of Republic Act (R.A.) No. 7691, as well as Section 1, Rule 70 of the Rules of Court, clearly provides that forcible entry and unlawful detainer cases fall within the exclusive original jurisdiction of Metropolitan Trial Courts, Municipal Trial Courts and Municipal Circuit Trial Courts. Hence, as the MTCC has jurisdiction over the action, the question whether or not the suit was brought in the place where the land in dispute is located was no more than a matter of venue and the court, in the exercise of its jurisdiction over the case, could determine whether venue was properly or improperly laid. 4. Eastern Mediterranean vs. Surio (NLRC had no appellate jurisdiction to review the decision of the POEA in disciplinary cases involving overseas contract workers)

money claims arising out of employer-employee relationships involving overseas Filipino workers in the Labor Arbiters Jurisdiction over such claims was previously exercised by the POEA POEA dismissed the complaint for disciplinary action. Petitioners filed a partial appeal in the NLRC, still maintaining that respondents should be administratively sanctioned NLRC dismissed petitioners appeal for lack of jurisdiction. Commission has no jurisdiction to review cases decided by the POEA Administrator involving disciplinary actions. Petitioners filed certiorari and mandamus. CA dismissed the petition. NLRC had no appellate jurisdiction to review the matter

Issue:

WHETHER OR NOT THE NLRC HAS JURISDICTION TO REVIEW ON APPEAL CASES DECIDED BY THE POEA ON MATTERS PERTAINING TO DISCIPLINARY ACTIONS AGAINST PRIVATE RESPONDENTS. Held: Although Republic Act No. 8042 transferred the original and exclusive jurisdiction to hear and decide money claims involving overseas Filipino workers from the POEA to the Labor Arbiters, the law did not remove from the POEA the original and exclusive jurisdiction to hear and decide all disciplinary action cases and other special cases administrative in character involving such workers. NLRC had no appellate jurisdiction to review the decision of the POEA in disciplinary cases involving overseas contract workers. When Republic Act No. 8042 withheld the appellate jurisdiction of the NLRC in respect of cases decided by the POEA, the appellate jurisdiction was vested in the Secretary of Labor petitioners should have appealed the adverse decision of the POEA to the Secretary of Labor instead of to the NLRC.

Facts: Respondents were former crewmembers of MT Seadance, a vessel owned by petitioner While respondents were still on board the vessel, they experienced delays in the payment oftheir wages. International Transport Federation boarded the vessel and found the wages of the respondents to be below the prevailing rates. Vessel owner paid them wage differentials and order their immediate repatriation to the Philippines On December 23, 1993, petitioners filed against the respondents a complaint for disciplinary action based on breach of discipline and for the reimbursement of the wage increases in POEA. During the pendency of the administrative complaint in the POEA, Republic Act No. 8042 (Migrant Workers and Overseas Filipinos Act of 1995) took effect on July 15, 1995. It vested original and exclusive jurisdiction over all