Republic Act No. 8369 October 28, 1997
- No person shall
AN ACT ESTABLISHING FAMILY COURTS,
GRANTING THEM EXCLUSIVE ORIGINAL
JURISDICTION OVER CHILD AND FAMILY CASES,
AMENDING BATAS PAMBANSA BILANG 129,AS
AMENDED, OTHERWISE KNOWN AS ACT OF
1980, APPROPRIATING FUNDS THEREFOR AND
FOR OTHER PURPOSES
Be it enacted by the Senate and House of
Representatives of the Philippines in Congress
assembled::
Section 1. Title. - This Act shall be known as
the "Family Courts Act of 1997".
Section 2. Statement of National Policies. - The
State shall protect the rights and promote the welfare
of children in keeping with the mandate of the
Constitution and the precepts of the United Nations
Convention on the rights of the Child. The State shall
provide a system of adjudication for youthful offenders
which takes into account their peculiar circumstances.
The State recognizes the sanctity of family life and
shall protect and strengthen the family as a basic
autonomous social institution. The courts shall
preserve the solidarity of the family, provide
procedures for the reconciliation of spouses and the
amicable settlement of family controversy.
Section 3. Establishment of Family Courts. - There
shall be established a Family Court in every province
and city in the country. In case where the city is the
capital of the province, the Family Court shall be
established in the municipality which has the highest
population.
Section 4. Qualification and Training of Family
Court Judges. - Sec. 15 of Batas Pambansa Blg.
129, as amended, is hereby further amended to read
as follows:
"Sec. 15. (a) Qualification.
be appointed Regional Trial Judge or
Presiding Judge of the Family Court unless
he is a natural-born citizen of the Philippines,
at least thirty-five (35) years of age, and, for
at least ten (10) years, has been engaged in
the practice of law in the Philippines or has
held a public office in the Philippines
requiring admission to the practice of law as
indispensable requisite.
"(b) Training of Family Court Judges. - The
Presiding Judge, as well as the court
personnel of the Family Courts, shall
undergo training and must have the
experience and demonstrated ability in
dealing with child and family cases.
"The Supreme Court shall provide a
continuing education program on child and
family laws, procedure and other related
disciplines to judges and personnel of such
courts."
Section 5. Jurisdiction offamily Courts. - The
Family Courts shall have exclusive original jurisdiction
to hear and decide the following cases:
a) Criminal cases where one or more of the
accused is below eighteen (18) years of age
but not less than nine (9) years of age but
not less than nine (9) years of age or where
one or more of the victims is a minor at the
time of the commission of the offense:
Provided, That if the minor is found guilty,
the court shall promulgate sentence and
ascertain any civil liability which the accused
may have incurred.
The sentence, however, shall be suspended
without need of application pursuant to
Ptesidential Decree No. 603, otherwise
known as the "Child and Youth Welfare
Code";
b) Petitions for guardianship, custody of
children, habeas corpus in relation to the
latter;
c) Petitions for adoption of children and the
revocation thereof;
d) Complaints for annulment of marriage,
declaration of nullity of marriage and those
relating to marital status and property
relations of husband and wife or those living
together under different status and
agreements, and petitions for dissolution of
conjugal partnership of gains;
e) Petitions for support and/or
acknowledgment;
f) Summary judicial proceedings brought
under the provisions of Executive Order No.
209, otherwise known as the "Family Code
of the Philippines";
g) Petitions for declaration of status of
children as abandoned, dependent o
neglected children, petitions for voluntary or
involuntary commitment of children; the
suspension, termination, or restoration of
parental authority and other cases
cognizable under Presidential Decree No.
603, Executive Order No. 56, (Series of
1986), and other related laws;
h) Petitions for the constitution of the family
home;
i) Cases against minors cognizable under
the Dangerous Drugs Act, as amended;
j) Violations of Republic Act No. 7610,
otherwise known as the "Special Protection
of Children Against Child Abuse, Exploitation
and Discrimination Act," as amended by
Republic Act No. 7658; and
k) Cases of domestic violence against:
1) Women - which are acts of
gender based violence that results,
or are likely to result in physical,
sexual or psychological harm or
suffering to women; and other
forms of physical abuse such as
battering or threats and coercion
which violate a woman's
personhood, integrity and freedom
movement; and
2) Children - which include the
commission of all forms of abuse,
neglect, cruelty, exploitation,
violence, and discrimination and all
other conditions prejudicial to their
development.
If an act constitutes a criminal offense, the accused or
batterer shall be subject to criminal proceedings and
the corresponding penalties.
If any question involving any of the above matters
should arise as an incident in any case pending in the
regular courts, said incident shall be determined in
that court.
Section 6. Use of Income. - All Family Courts shall
be allowed the use of ten per cent (10%) of their
income derived from filing and other court fees under
Rule 141 of the Rules of Court for research and other
operating expenses including capital outlay: Provided,
That this benefit shall likewise be enjoyed by all
courts of justice.
The Supreme Court shall promulgate the necessary
guidelines to effectively implement the provisions of
this Sec.
Section 7. Special Provisional Remedies. - In
cases of violence among immediate family members
living in the same domicile or household, the Family
Court may issue a restraining order against the
accused of defendant upon verified application by the
complainant or the victim for relief from abuse.
The court may order the temporary custody of
children in all civil actions for their custody. The court
may also order support pendente lite, including
deduction from the salary and use of conjugal home
and other properties in all civil actions for support.
Section 8. Supervision of Youth Detention
Homes. - The judge of the Family Court shall have
direct control and supervision of the youth detention
home which the local government unit shall establish
to separate the youth offenders from adult criminals:
Provided, however, That alternatives to detention and
institutional care shall be made available to the
accused including counseling, recognizance, bail,
community continuum, or diversions from the justice
system: Provided, further, That the human rights of
the accused are fully respected in a manner
appropriate to their well-being.
Section 9. Social Services and Counseling
Division. - Under the guidance ofthe Department of
Social Welfare and Development (DSWD), a Social
Services and Counseling Division (SSCD) shall be
established in each judicial region as the Supreme
Court shall deem necessary based on the number of
juvenile and family cases existing in such jurisdiction.
It shall provide appropriate social services to all
juvenile and family cases filed with the court and
recommend the proper social action. It shall also
develop programs, formulate uniform policies and
procedures, and provide technical supervision and
monitoring of all SSCD in coordination with the judge.
Section 10. Social Services and Counseling
Division Staff. - The SSCD shall have a staff
composed of qualified social workers and other
personnel with academic preparation in behavioral
sciences to carry out the duties'of conducting intake
assessment, social case studies, casework and
counseling, and othersocial services that may be
needed in connection with cases filed with the court:
Provided, however, That in adoption cases and in
petitions for declaration of abandonment, the case
studies may be prepared by social workers of duly
licensed child caring or child placement agencies, or
the DSWD. When warranted, the division shall
recommend that the court avail itself of consultative
services of psychiatrists, psychologists, and other
qualified specialists presently employed in other
departments of the government in connection with its
cases.
The position of Social Work Adviser shall be created
under the Office of the Court Administrator, who shall
monitor and supervise the SSCD ofthe Regional Trial
Court.
Section 11. Alternative Social Services. - In
accordance with Sec. 17 of this Act, in areas where
no Family Court has been established or no Regional
Trial Court was designated by the Supreme Court due
to the limited number of cases, the DSWD shall
designate and assign qualified, trained, and DSWD
accredited social workers of the local government
units to handle juvenile and family cases filed in the
designated Regional Trial Court of the place.
Section 12. Privacy and Confidentiality of
Proceedings. - All hearings and conciliation of the
child and family cases shall be treated in a manner
consistent with the promotion of the child's and the
family's dignity and worth, and shall respect their
privacy at all stages of the proceedings. Records of
the cases shall be dealt with utmost confidentiality
and the identity of parties shall not be divulged unless
necessary and with authority of the judge.
Section 13. Special Rules of Procedure. - The
Supreme Court shall promulgate special rules of
procedure for the transfer of cases to the new courts
during the transition period and for the disposition of
family cases with the best interests of the child and
the protection of the family as primary consideration
taking into account the United Nations Convention on
the Rights of the Child.
Section 14. Appeals. - Decisions and orders of the
court shall be appealed in the same manner and
subject to the same conditions as appeals from the
ordinary Regional Trial Courts.
Section 15. Appropriations. - The amount
necessary to carry out the provisions of this Act shall
be included in the General Appropriations Act of the
year following in its enactment into law and thereafter.
Section 16. Implementing Rules and
Regulations. - The Supreme Court, in coordination
with the DSWD, shall formulate the necessary rules
and regulations for the effective implementation of the
social aspects of this Act.
Section 17. Transitory Provisions. - Pending the
establishment of such Family Courts, the Supreme
Court shall designate from among the branches ofthe
Regional Trial Court at least one Family Court in each
of the cities of Manila, Quezon, Pasay, Caloocan,
Makati, Pasig, Mandaluyong, Muntinlupa, Laoag,
Baguio, Santiago, Dagupan, Olongapo, Cabanatuan,
San Jose, Angeles, Cavite, Batangas, Lucena, Naga,
Iriga, Legazpi, Roxas, Iloilo, Bacolod, Dumaguete,
Tacloban, Cebu, Mandaue, Tagbilaran, Surigao,
Butuan, Cagayan de Oro, Davao, General Santos,
Oroquieta, Ozamis, Dipolog, Zamboanga, Pagadian,
Iligan, and in such other places as the Supreme Court
may deem necessary.
Additional cases other than those provided in Sec. 5
may be assigned to the Family Courts when their
dockets permit: Provided, That such additional cases
shall not be heard on the same day family cases are
heard.
In areas where there are no Family Courts, the cases
referred to in Sec. 5 of this Act shall be adjudicated by
the Regional Trial Court.
Section 18. Separability Clause. - In case any
provision of this Act is declared unconstitutional, the
other provisions shall remain in effect.
Section 19. Repealing Clause. - All other laws,
decrees, executive orders, rules or regulations
inconsistent herewith are hereby repealed, amended
or modified accordingly.
Section 20. Effectivity. - This Act shall take effect
fifteen (15) days after its publication in at least two (2)
national newspapers of general circulation.
Approved October 28, 1997.
Thornton v. Thornton, G.R. No. 154598, Aug. 16,
2004
FACTS: Petitioner was an American, respondent was
a Filipino. They were married and had one daughter.
After 3 years, the woman grew restless and bored as
a plain housewife and wanted to return to her old job
as GRO in a nightclub. One day, the woman left the
family home together with their daughter and told her
servants that she was going to Basilan. The husband
filed a petition for habeas corpus in the designated
Family Court in Makati City but was dismissed
because the child was in Basilan. When he went to
Basilan, he didnt find them and the barangay office
issued a certification that respondent was no longer
residing there. Petitioner filed another petition for
habeas corpus in CA which could issue a writ of
habeas corpus enforceable in the entire country. The
petition was denied by CA on the ground that it did
not have jurisdiction over the case since RA 8369
(Family Courts Act of 1997) gave family courts
exclusive jurisdiction over petitions for habeas corpus,
it impliedly repealed RA 7902 (An Act Expanding the
Jurisdiction of CA) and B.P 129 (The judiciary
Reorganization Act of 1980.)
ISSUE: W/N CA has jurisdiction to issue writs of
habeas corpus in cases involving custody of minors in
light of the provision in RA 8369 giving family courts
exclusive jurisdiction over such petitions.

HELD: Petition granted. CA should take cognizance
of the case because nothing in RA 8369 revoked its
jurisdiction to issue writs of habeas corpus involving
custody of minors. The reasoning of CA cant be
affirmed because it will result to iniquitous, leaving
petitioners without legal course in obtaining custody.
The minor could be transferred from one place to
another and habeas corpus case will be left without
legal remedy since family courts take cognizance only
cases within their jurisdiction. Literal interpretation
would render it meaningless, lead to absurdity,
injustice, and contradiction. The literal interpretation of
exclusive will result in grave injustice and negate the
policy to protect the rights and promote welfare of
children.
Ada vs Baylon G.R. No. 182435; Aug.
13, 2012
Facts: This case involves the estate of
spouses Florentino Baylon and
Maximina Elnas Baylon (Spouses
Baylon) who died on November 7,
1961 and May 5, 1974, respectively.
At the time of their death, Spouses
Baylon were survived by their
legitimate children, namely, Rita
Baylon (Rita), Victoria Baylon
(Victoria), Dolores Baylon (Dolores),
Panfila Gomez (Panfila), Ramon Baylon
(Ramon) and herein petitioner Lilia B.
Ada (Lilia). Dolores died intestate and
without issue on August 4, 1976.
Victoria died on November 11, 1981
and was survived by her daughter,
herein petitioner Luz B. Adanza.
Ramon died intestate on July 8, 1989
and was survived by herein
respondent Florante Baylon (Florante),
his child from his first marriage, as
well as by petitioner Flora Baylon, his
second wife, and their legitimate
children, namely, Ramon, Jr. and
herein petitioners Remo, Jose, Eric,
Florentino and Ma. Ruby, all surnamed
Baylon.
Petitioners filed with the RTC
complaint for partition, accounting,
and damages against respondent
Florante, Rita, and Panfila. They
alleged that Spouses Baylon owned 43
parcels of land. They claimed that Rita
took possession of the land and
appropriated the income derived
therefrom. Florante, Rita and Panfila
asserted, in their answer, that the co-
owned the properties in question. On
July 1997, Rita donated a parcel of
land to Florante. In July 2000, Rita
died. Petitioners learned of the
donation made by Rita in favor of
Florante. They filed for a Supplemental
Pleading, asking the court to rescind
the Deed of Donation.
Ruling: Misjoinder of Causes of Action
The complaint filed by the petitioners
with the RTC involves two separate,
distinct and independent actions
partition and rescission. First, the
petitioners raised the refusal of their
co-heirs, Florante, Rita and Panfila, to
partition the properties which they
inherited from Spouses Baylon.
Second, in their supplemental
pleading, the petitioners assailed the
donation inter vivos of Lot No. 4709
and half of Lot No. 4706 made by Rita
in favor of Florante pendente lite. The
actions of partition and rescission
cannot be joined in a single action. By
a joinder of actions, or more properly,
a joinder of causes of action is meant
the uniting of two or more demands or
rights of action in one action, the
statement of more than one cause of
action in a declaration. It is the union
of two or more civil causes of action,
each of which could be made the basis
of a separate suit, in the same
complaint, declaration or petition. A
plaintiff may under certain
circumstances join several distinct
demands, controversies or rights of
action in one declaration, complaint or
petition.29 The objectives of the rule
or provision are to avoid a multiplicity
of suits where the same parties and
subject matter are to be dealt with by
effecting in one action a complete
determination of all matters in
controversy and litigation between the
parties involving one subject matter,
and to expedite the disposition of
litigation at minimum cost. The
provision 29 Republic v. Hernandez,
323 Phil. 606, 624-625 (1996).
Decision 9 G.R. No. 182435 should be
construed so as to avoid such
multiplicity, where possible, without
prejudice to the rights of the
litigants.30 Nevertheless, while parties
to an action may assert in one
pleading, in the alternative or
otherwise, as many causes of action
as they may have against an opposing
party, such joinder of causes of action
is subject to the condition, inter alia,
that the joinder shall not include
special civil actions governed by
special rules.31 Here, there was a
misjoinder of causes of action. The
action for partition filed by the
petitioners could not be joined with
the action for the rescission of the said
donation inter vivos in favor of
Florante. Lest it be overlooked, an
action for partition is a special civil
action governed by Rule 69 of the
Rules of Court while an action for
rescission is an ordinary civil action
governed by the ordinary rules of civil
procedure. The variance in the
procedure in the special civil action of
partition and in the ordinary civil
action of rescission precludes their
joinder in one complaint or their being
tried in a single proceeding to avoid
confusion in determining what rules
shall govern the conduct of the
proceedings as well as in the
determination of the presence of
requisite elements of each particular
cause of action.32 A misjoined cause
of action, if not severed upon motion
of a party or by the court sua sponte,
may be adjudicated by the court
together with the other causes of
action. Nevertheless, misjoinder of
causes of action is not a ground for
dismissal. Indeed, the courts have the
power, acting upon the motion of a
party to the case or sua sponte, to
order the severance of the misjoined
cause of action to be proceeded with
separately.33 However, if there is no
30 Id. at 625. 31 THE RULES OF
COURT, Rule 2, Section 5. 32 See
Francisco, Remedial Law Compendium,
Vol. 1, 9th Rev. Ed., p. 77. 33 THE
RULES OF COURT, Rule 2, Section 6.
Decision 10 G.R. No. 182435 objection
to the improper joinder or the court
did not motu proprio direct a
severance, then there exists no bar in
the simultaneous adjudication of all
the erroneously joined causes of
action. On this score, our disquisition
in Republic of the Philippines v.
Herbieto34 is instructive, viz: This
Court, however, disagrees with
petitioner Republic in this regard. This
procedural lapse committed by the
respondents should not affect the
jurisdiction of the MTC to proceed with
and hear their application for
registration of the Subject Lots. x x x x
Considering every application for land
registration filed in strict accordance
with the Property Registration Decree
as a single cause of action, then the
defect in the joint application for
registration filed by the respondents
with the MTC constitutes a misjoinder
of causes of action and parties.
Instead of a single or joint application
for registration, respondents Jeremias
and David, more appropriately, should
have filed separate applications for
registration of Lots No. 8422 and
8423, respectively. Misjoinder of
causes of action and parties do not
involve a question of jurisdiction of the
court to hear and proceed with the
case. They are not even accepted
grounds for dismissal thereof. Instead,
under the Rules of Court, the
misjoinder of causes of action and
parties involve an implied admission of
the courts jurisdiction. It
acknowledges the power of the court,
acting upon the motion of a party to
the case or on its own initiative, to
order the severance of the misjoined
cause of action, to be proceeded with
separately (in case of misjoinder of
causes of action); and/or the dropping
of a party and the severance of any
claim against said misjoined party,
also to be proceeded with separately
(in case of misjoinder of parties).35
(Citations omitted) It should be
emphasized that the foregoing rule
only applies if the court trying the
case has jurisdiction over all of the
causes of action therein
notwithstanding the misjoinder of the
same. If the court trying the case has
no jurisdiction over a misjoined cause
of action, then such misjoined cause of
action has to be severed from the
other causes of action, and if not so
severed, any adjudication rendered by
the court with respect to the same
would be a nullity. 34 498 Phil. 227
(2005). 35 Id. at 237-239. Decision 11
G.R. No. 182435 Here, Florante posed
no objection, and neither did the RTC
direct the severance of the petitioners
action for rescission from their action
for partition. While this may be a
patent omission on the part of the
RTC, this does not constitute a ground
to assail the validity and correctness
of its decision. The RTC validly
adjudicated the issues raised in the
actions for partition and rescission
filed by the petitioners. Asserting a
New Cause of Action in a
Supplemental Pleading In its Decision
dated October 26, 2007, the CA
pointed out that the said action for
rescission should have been filed by
the petitioners independently of the
proceedings in the action for partition.
It opined that the action for rescission
could not be lumped up with the
action for partition through a mere
supplemental pleading. We do not
agree. A supplemental pleading may
raise a new cause of action as long as
it has some relation to the original
cause of action set forth in the original
complaint. Section 6, Rule 10 of the
Rules of Court reads: Sec. 6.
Supplemental Pleadings. Upon
motion of a party the court may, upon
reasonable notice and upon such
terms as are just, permit him to serve
a supplemental pleading setting forth
transactions, occurrences or events
which have happened since the date
of the pleading sought to be
supplemented. The adverse party may
plead thereto within ten (10) days
from notice of the order admitting the
supplemental pleading. In Young v.
Spouses Sy,36 this Court had the
opportunity to elucidate on the
purpose of a supplemental pleading.
Thus: 36 534 Phil. 246 (2006).
Decision 12 G.R. No. 182435 As its
very name denotes, a supplemental
pleading only serves to bolster or add
something to the primary pleading. A
supplement exists side by side with
the original. It does not replace that
which it supplements. Moreover, a
supplemental pleading assumes that
the original pleading is to stand and
that the issues joined with the original
pleading remained an issue to be tried
in the action. It is but a continuation of
the complaint. Its usual office is to set
up new facts which justify, enlarge or
change the kind of relief with respect
to the same subject matter as the
controversy referred to in the original
complaint. The purpose of the
supplemental pleading is to bring into
the records new facts which will
enlarge or change the kind of relief to
which the plaintiff is entitled; hence,
any supplemental facts which further
develop the original right of action, or
extend to vary the relief, are available
by way of supplemental complaint
even though they themselves
constitute a right of action.37
(Citations omitted and emphasis ours)
Thus, a supplemental pleading may
properly allege transactions,
occurrences or events which had
transpired after the filing of the
pleading sought to be supplemented,
even if the said supplemental facts
constitute another cause of action.
Admittedly, in Leobrera v. Court of
Appeals, 38 we held that a
supplemental pleading must be based
on matters arising subsequent to the
original pleading related to the claim
or defense presented therein, and
founded on the same cause of action.
We further stressed therein that a
supplemental pleading may not be
used to try a new cause of action.
However, in Planters Development
Bank v. LZK Holdings and
Development Corp., 39 we clarified
that, while a matter stated in a
supplemental complaint should have
some relation to the cause of action
set forth in the original pleading, the
fact that the supplemental pleading
technically states a new cause of
action should not be a bar to its
allowance but only a matter that may
be considered by the court in the
exercise of its 37 Id. at 260. 38 252
Phil. 737 (1989). 39 496 Phil. 263
(2005). Decision 13 G.R. No. 182435
discretion. In such cases, we stressed
that a broad definition of cause of
action should be applied. Here, the
issue as to the validity of the donation
inter vivos of Lot No. 4709 and half of
Lot No. 4706 made by Rita in favor of
Florante is a new cause of action that
occurred after the filing of the original
complaint. However, the petitioners
prayer for the rescission of the said
donation inter vivos in their
supplemental pleading is germane to,
and is in fact, intertwined with the
cause of action in the partition case.
Lot No. 4709 and half of Lot No. 4706
are included among the properties
that were sought to be partitioned.
The petitioners supplemental
pleading merely amplified the original
cause of action, on account of the
gratuitous conveyance of Lot No. 4709
and half of Lot No. 4706 after the filing
of the original complaint and prayed
for additional reliefs, i.e., rescission.
Indeed, the petitioners claim that the
said lots form part of the estate of
Spouses Baylon, but cannot be
partitioned unless the gratuitous
conveyance of the same is rescinded.
Thus, the principal issue raised by the
petitioners in their original complaint
remained the same.
Barrido vs Nonato; G.R. No. 176492;
Oct.20, 2014
Facts: In the course of the marriage of
respondent Leonardo V. Nonato and
petitioner Marietta N. Barrido,they
were able to acquire a property
situated in Eroreco, Bacolod City,
consisting ofa house and lot, covered
by Transfer Certificate of Title (TCT)
No. T-140361. On March 15, 1996,
their marriage was declared void on
the ground of psychological incapacity.
Since there was no more reason to
maintain their co-ownership over the
property, Nonato asked Barrido for
partition, but the latter refused. Thus,
on January 29, 2003, Nonato filed a
Complaint for partition before the
Municipal Trial Court in Cities (MTCC)
of Bacolod City, Branch 3.
Barrido claimed, by way of affirmative
defense, that the subject property had
already been sold to their children,
Joseph Raymund and Joseph Leo. She
likewise moved for the dismissal of the
complaint because the MTCC lacked
jurisdiction, the partition case being
an action incapable of pecuniary
estimation.
The MTCC adjudicated the house and
lot to Marietta Nonato. Nonato
appealed the MTCC Decision before
the RTC. On July 21, 2004, the Bacolod
RTC reversed the ruling of the MTCC. It
found that even though the MTCC
aptly applied Article 129 of the Family
Code, it nevertheless made a
reversible error in adjudicating the
subject property to Barrido.
Issue: Does the MTCC have
jurisdiction?
Ruling: Contrary to Barridos
contention, the MTCC has jurisdiction
to take cognizance of real actions or
those affecting title to real property, or
for the recovery of possession, or for
the partition or condemnation of, or
foreclosure of a mortgage on real
property.7 Section 33 of Batas
Pambansa Bilang 1298 provides:
Section 33. Jurisdiction of Metropolitan
Trial Courts, Municipal Trial Courts and
Municipal Circuit Trial Courts in civil
cases. Metropolitan Trial Courts,
Municipal Trial Courts, and Municipal
Circuit
Trial Courts shall exercise:
(3) Exclusive original jurisdiction in all
civil actions which involve title to, or
possession of, real property, or any
interest therein where the assessed
value of the propertyor interest therein
does not exceed Twenty thousand
pesos (P20,000.00)or, in civil actions
in Metro Manila, where such assessed
value does not exceed Fifty thousand
pesos (P50,000.00) exclusive of Here, the subject propertys assessed
interest, damages of whatever kind, value was merely P8,080.00, an
attorney's fees, litigation expenses amount which certainly does not
and costs: Provided, That value of exceed the required limit of
such property shall be determined by P20,000.00 for civil actions outside
the assessed value of the adjacent Metro Manila tofall within the
lots. (as amended by R.A. No. 7691)9 jurisdiction of the MTCC. Therefore, the
lower court correctly took cognizance
of the instant case.