G.R. No.

189434 March 12, 2014

Ferdinand R. Marcos, Jr., Petitioner,
Vs.
Republic of the Philippines, represented by the Presidential Commission on Good
Government, Respondent.

Sereno, C.J.

Facts:
In this case, the petitioners seek the reconsideration of the Court’s decision declaring all
the assets of Arelma, S.A., an entity created by the late Ferdinand E. Marcos, forfeited in favor
of the Republic of the Philippines. The petitioners argue that the Sandiganbayan does not possess
territorial jurisdiction over the res or the Arelma proceeds, which are held by Merrill Lynch in
the United States. It is the petitioners’ theory that the Sandiganbayan must first acquire territorial
jurisdiction over the Arelma proceeds before the judgment may be enforced.

Issue: Did the Sandiganbayan acquire jurisdiction over the res in the instant case?

Ruling:
Yes. Jurisdiction over the res is acquired either (a) by the seizure of the property under
legal process, whereby it is brought into actual custody of the law; or (b) as a result of the
institution of legal proceedings, in which the power of the court is recognized and made
effective. In the latter condition, the property, although at all times within the potential power of
the court, may not be in actual custody of said court.
The Court, in citing Perkins vs. Dizon, held that “in order that the court may exercise
power over the res, it is not necessary that the court should take actual custody of the property,
potential custody thereof being sufficient. There is potential custody when, from the nature of the
action brought, the power of the court over the property is impliedly recognized by law.

G.R. No. 188832 April 23, 2014

Vivencio B. Villagracia, Petitioner,
Vs.
Fifth (5th) Shari’a District Court and Roldan E. Mala, Respondents.

Leonen, J.

Facts:
Roldan E. Mala purchased a parcel of land located in Poblacion, Parang, Maguindanao,
now Shariff Kabunsuan, from Ceres Canete. A transfer certificate of title was issued in Roldan’s
name. At the time of the purchase, Vivencio B. Villagracia occupied the parcel of land. Vivencio
secured a Katibayan ng Orihinal na Titulo issued by the Land Registration Authority allegedly
covering the same parcel of land.
 After failing to settle his conflicting claim with Vivencio at the barangay level, Roldan
filed an action to recover the possession of the parcel of land with respondent Fifth Shari’a
District Court, which took cognizance of the case.

Issue:
May a Shari’a District Court validly hear, try, and decide a real action where one of the parties is
a non-Muslim?

Ruling:
No. The Fifth Shari’a District Court had no jurisdiction to hear, try, and decide Roldan’s
action for recovery of possession. The law conferring jurisdiction to Shari’a District Courts is the
Code of the Muslim Personal Laws of the Philippines. Under Art. 143 thereof, Shari’a Courts
have concurrent original jurisdiction with existing civil courts over real actions not arising from
customary contracts wherein the parties involved are Muslims.
When the property involved is real, the action to recover it is a real action. In such
actions, the parties involved must be Muslims for Shari’a District Courts to validly take
cognizance of them.
In this case, Vivencio is not a Muslim. The respondent court should have motu propio
dismissed the case because it had no jurisdiction over the subject matter of the action.

G.R. No. 184203 November 26, 2014

City of Lapu-Lapu, Petitioner,
Vs.
Philippine Economic Zone Authority, Respondent.

Leonen, J.

Facts:

The City of Lapu-Lapu made several demands on the Philippine Economic Zone Authority
(PEZA) for the payment of real property tax. The PEZA filed a petition for declaratory relief
with the RTC of Pasay City, praying that the trial court declare it exempt from payment of real
property tax. Both the RTC of Pasay City and the Court of Appeals ruled that PEZA is exempt
from payment of real property tax.

The City of Lapu-Lapu insists that the trial court had no jurisdiction to hear PEZA’s petition for
declaratory relief because the case involved real property located in the City of Lapu-Lapu.

Issue: Does the Regional Trial Court have jurisdiction to hear, try and decide PEZA’s petition
for declaratory relief?

Ruling:
No. In the present case, the Regional Trial Court had no jurisdiction over the subject
matter of the action, specifically, over the remedy sought. Instead of a petition for declaratory
relief, the PEZA should have directly resorted to a judicial action. The PEZA should have filed a
complaint for injunction, the appropriate ordinary civil action to enjoin the City from enforcing
its demand and collecting the assessed taxes from PEZA.

G.R. No. 199660 July 13, 2015

U-BIX CORPORATION AND EDILBERTO BRAVO, Petitioners,

Vs.
VALERIE ANNE H. HOLLERO, Respondent.

Del Castillo, J.

Facts:
Petitioners filed a complaint against respondent for reimbursement of training costs with
the NLRC. On the other hand, the respondent filed against petitioners a complaint for illegal
dismissal. The Labor Arbiter found that the dismissal of the respondent was valid and ordered
the reimbursement of the amount spent for her training. However, the NLRC reversed the Labor
Arbiter’s decision. The Court of Appeals also denied the petitioners’ petition for certiorari. In a
Decision, the Supreme Court affirmed the decision of the Court of Appeals. Subsequently, the
respondent filed a Motion for Issuance of Writ of Execution before the Labor Arbiter when the
Decision became final and executory.
In assailing the recomputed amount to be paid to the respondent as a consequence of the
final and executor decision of the Court, the petitioners posted a supersedeas bond issued by
Mapfre Insular Insurance Corporation. The NLRC held that the supersedeas bond posted by
petitioners has no force and effect because the Certification of Accreditation and Authority for
said supersedeas bond covers civil and special proceedings cases only, and does not cover labor
cases. Hence, according to the NLRC, U-Bix failed to perfect its appeal.

Issue:
Should the petitioners’ appeal be dismissed outright on the ground that the accompanying
supersedeas bond is invalid?

Ruling:
Yes, the appeal should be dismissed outright on the ground that the accompanying
supersedeas bond is invalid.
Perfection of an appeal in the manner and within the period prescribed by law is not only
mandatory, but jurisdictional. Failure to conform to the rules will render the judgment sought to
be reviewed final and executory. The requirements for perfecting an appeal must, as a rule, be
strictly followed. Such requirements are considered indispensable interdictions against needless
delay and are necessary for the orderly discharge of the judicial business. It must be emphasized
that the policy of liberal interpretation is qualified by the requirement that there must be
exceptional circumstances to allow the relaxation of the rules. Absent exceptional circumstances,
certain procedural precepts must remain inviolable.