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ELISA ANGELES vs.

COURT OF APPEALS
G.R. No. 178733, September 15, 2014

Facts:

A complaint for annulment of real estate mortgage, foreclosure sale, reconveyance and
damages as Civil Case No. 69213 was filed by spouses Juan and Anatalia Coronel (the Coronels)
against herein petitioner Elisa Angeles and several others. The trial court rendered judgment in
favor of the Coronels. Angeles filed a notice of appeal while the Coronels filed a motion for
execution on April 3, 2005 judgment pending appeal which was denied by the trial court.
Angeles appeal to the CA was docketed as CA-G.R. CV No. 86451.
In a November 15, 2005 Order, the trial court directed that the entire record of Civil Case No.
69213 be transmitted to the CA for appropriate action. In a February 1, 2006 Order, the trial
court reconsidered its October 19, 2005 Order and thus granted the Coronels motion for
execution pending appeal. A Writ of Execution Pending Appeal was thus issued on February 16,
2006. On February 27, 2006, the record of Civil Case No. 69213 was transmitted to the CA. On
March 9, 2006, petitioner was evicted from the subject property as a result of the enforcement of
the Writ of Execution Pending Appeal.

Issue: Whether the trial court has the authority to grant the execution pending appeal.

Ruling:

Yes. The trial court had the authority to grant execution pending appeal on February 1,
2006 and issue the writ on February 15, 2006. The record of Civil Case No. 69213 was
transmitted to the CA only on February 27, 2006.Prior to the transmittal of the original record;
the trial court may order execution pending appeal. The residual jurisdiction of trial courts is
available at a stage in which the court is normally deemed to have lost jurisdiction over the case
or the subject matter involved in the appeal. This stage is reached upon the perfection of the
appeals by the parties or upon the approval of the records on appeal, but prior to the transmittal
of the original records or the records on appeal. In either instance, the trial court still retains its
so-called residual jurisdiction to issue protective orders, approve compromises, permit appeals of
indigent litigants, order execution pending appeal, and allow the withdrawal of the appeal.
Villareal et. al vs. People
G.R. No. 151258 December 1, 2014

Facts:
Leonardo "Lenny" Villa joined (Aquila Fraternity). Hazing was pre-requisite in joining
the fraternity. After the initiation Lenny was severely injured which lead to his death. A criminal
case for homicide was filed against the 35 Aquilans in Branch 121 of RTC Caloocan. Four of the
accused (Tecson, et. al.) were found to be guilty of homicide by the trial court but was reduced to
crime of slight physical injuries and sentenced to 20 days of arresto menor by the Court of
Appeals. However, upon appeal to the Supreme Court by the Office of the Solicitor General, the
Supreme Court ruled that they should be liable for reckless imprudence resulting in homicide
instead.
In Motions for Clarification or Reconsideration, Tecson et. al. clarified the effect of the
decision of the Supreme Court to their criminal liability. According to Tecson et. al., they
immediately applied for probation after the CA rendered its Decision lowering their criminal
liability from the crime of homicide, which carries a non-probationable sentence, to slight
physical injuries, which carries a probationable sentence. Hence, they have already been
discharged from their criminal liability and the cases against them closed and terminated by
virtue of their granted Applications for Probation in Branch 130 of RTC Caloocan for which the
terms therein are already been complied with.
Issue: Whether Tecson et.al properly filed their application for probation in Branch 130 of RTC
Caloocan?

Ruling:

No. The applicants are not at liberty to choose the forum in which they may seek
probation. The probation proceedings were premised on an unwarranted exercise of authority
hence the RTC Branch 130 never acquired jurisdiction over the case.
The records of the case were still with the CA when RTC Branch 130 granted the
probation applications. Jurisdiction over a case is lodged with the court in which the criminal
action has been properly instituted. If a party appeals the trial court’s judgment or final
order, jurisdiction is transferred to the appellate court. The execution of the decision is thus
stayed insofar as the appealing party is concerned. The court of origin then loses jurisdiction over
the entire case the moment the other party’s time to appeal has expired. Any residual jurisdiction
of the court of origin shall cease – including the authority to order execution pending appeal –
the moment the complete records of the case are transmitted to the appellate court. Consequently,
it is the appellate court that shall have the authority to wield the power to hear, try, and decide
the case before it, as well as to enforce its decisions and resolutions appurtenant thereto. That
power and authority shall remain with the appellate court until it finally disposes of the case.
Jurisdiction cannot be ousted by any subsequent event, even if the nature of the incident would
have prevented jurisdiction from attaching in the first place.
Supapo vs. Spouses de Jesus
G.R. No. 198356

Facts:

The Spouses Supapo filed a complaint for accion publiciana against Roberto and Susan
de Jesus with the MeTC of Caloocan City. The complaint sought to compel the respondents to
vacate a piece of land located in Quezon City and registered under petitioner's name. The land
has an assessed value of 39, 980 pesos.

Issue: Whether the MTC has jurisdiction?

Ruling:

Yes. Under BP 129, the jurisdiction of the RTC over actions involving title to or
possession of real property is plenary. However, RA 7691 granted the MeTC, MTC and MCTC
the exclusive original jurisdiction to hear actions where the assessed value of the property does
not exceed 20, 000 pesos to 50, 000 pesos if the property is located in Metro Manila. Jurisdiction
over actions involving title to or possession of real property is now determined by its assessed
value. It is its fair market value multiplied by the assessment level. In the present case, the
Spouses Supapo alleged that the assessed value of the subject lot located in Metro Manila is 39,
980 pesos. Thus, the MeTC properly acquired jurisdiction over the complaint for accion
publiciana.
De Vera vs. De Jesus
G.R. No. 179457 June 22, 2015

Facts:

Petitioners (De Vera) filed a complaint for reconveyance of ownership or possession


against the respondents. They alleged that they are the owners of land denominated as Lot. 7303.
However, the petitioners discovered that their lots were already covered by Free Patent Titles in
the names of Respondents (De Jesus). Respondents alleged that the MTC has no jurisdiction as
the combined assessed value of the property is more than ₱20,000.00; the case is within the
exclusive original jurisdiction of the RTC pursuant to Section 19, paragraph 2 of BP 129.

Issue: Whether the MTC has jurisdiction?

Ruling:

No. Under BP 129, jurisdiction in civil cases, the Regional Trial Courts shall exercise
exclusive original jurisdiction in all civil actions which involve the title to, or possession of, real
property, or any interest therein, where the assessed value of the property involved exceeds
Twenty thousand pesos (₱20,000.00) or for civil actions in Metro Manila, where such the value
exceeds Fifty thousand pesos (₱50,000.00) except actions for forcible entry into and unlawful
detainer of lands or buildings, original jurisdiction over which is conferred upon Metropolitan
Trial Courts, Municipal Trial Courts, and Municipal Circuit Trial Courts.

The petitioners failed to indicate the assessed value of the subject real property. At any
rate, based on the Tax Declarations attached to their complaint, the disputed land located in
Bolinao, Pangasinan, has a total assessed value of ₱54,370.00. Therefore, the RTC has
jurisdiction.