Bernabe L. Navida, et.al. vs. Hon. Teodoro A. Dizon, Jr., et.al. G.R. Nos.

125078, 125598, 126654, 127856 and 128398 February 10, 1997, April 28, 1997, March 10, 1999 Leonardo-Decastro, J: Facts: Beginning 1993, a number of personal injury suits were filed in different Texas state courts by citizens of twelve foreign countries, including the Philippines. The plaintiffs sought damages for injuries they allegedly sustained from their exposure to dibromochloropropane (DBCP), a chemical used to kill nematodes (worms), while working on farms in 23 foreign countries. The cases were eventually transferred to and consolidated in the Federal District Court for the Southern District of Texas, Houston Division. The defendants in the consolidated cases prayed for the dismissal of all the actions under the doctrine of forum non conveniens. In a Memorandum and Order dated July 11, 1995 the Federal District Court conditionally granted the defendants motion to dismiss. In accordance with the Memorandum and Order, a total of 336 plaintiffs from General Santos City filed a joint complaint in the RTC of General Santos City on August 10, 1995. The plaintiffs Navida et.al. prayed for the payment of damages in view of the illnesses and injuries to the reproductive systems which they allegedly suffered because of their exposure to DBCP. They claimed that their illnesses and injuries were due to the fault or negligence of each of the defendant companies. On May 20, 1996 without resolving the motions filed by the parties, the RTC of General Santos City issued an order dismissing the complaint on the ground that it did not have jurisdiction to hear the case since the subject matter stated in the complaint and which is uniquely particular to the present case, consisted of activity or course of conduct engaged in by foreign defendants outside Philippine territory, hence outside and beyond the jurisdiction of Philippine Courts, including the present Regional Trial Court. Another joint complaint for damages against respondent companies was filed before Branch 16 of the RTC of Davao City by 155 plaintiffs from Davao City. This is a similar complaint (Abella et.al.) to Navida et.al. According to Abella et.al., the RTC of Davao City has jurisdiction over the subject matter of the case since Articles 2176 and 1287 of the Civil Code are broad enough to cover the acts complained of and to support their claims for damages. Issue: Whether or not the RTC of General Santos City and the RTC of Davao City both acquired jurisdiction over the cases. Ruling: The Supreme Court held that the RTC of General Santos City and the RTC of Davao City both acquired jurisdiction over the civil cases. The rule is settled that jurisdiction over the subject matter of a case is conferred by law and is determined by the allegations in the complaint and the character of the relief sought, irrespective of whether the plaintiffs are entitled to all or some of the claims asserted therein. It is clear that the claim for damages is the main cause of action and that the total amount sought in the complaints is approximately P 2.7 million for each of the plaintiff claimants. The RTCs unmistakably have jurisdiction over the cases filed in General Santos City and Davao City, as both claims

by Navida, et. Al. and Abella et.al. fall within the purview of the definition of the jurisdiction of the RTC under the Batas Pambansa Blg. 129. Quite evidently, the allegations in the amended joint-complaints of Navida et.al. and Abella et.al. attributes to defendant companies certain acts and/or omissions which led to their exposure to nematocides containing the chemical DBCP. Thus, these allegations in the complaints constitute the cause of action of plaintiff-claimants a quasi-delict, which under the Civil Code is defined as an act or omission which causes damage to another, there being fault or negligence. The factual allegations in the Amended Joint-Complaints all point to their cause of action, which undeniably occurred in the Philippines. The RTC of General Santos City and RTC of Davao City obviously have reasonable basis to assume jurisdiction over the cases.

Celia S. Vda. De Herrera vs. Emelita Bernardo, et.al. G.R. No. 170251 June 1, 2011 Peralta, J: Facts: Respondents heirs of Crisanto S. Bernardo, represented by Emelita Bernardo, filed a complaint before the Commission on the Settlement of Land Problems (COSLAP) against Alfredo Herrera for interference, disturbance, unlawful claim, harassment and trespassing over a portion of a parcel of land situated at Barangay Dalig, Cardona, Rizal with an area of 7, 993 square meters. Respondents claimed that said parcel of land was originally owned by their predecessors-ininterest, Crisanto Bernardo and was later on acquired by Crisanto Bernardo. The parcel of land was later on covered by a tax declaration under the name of the respondents. Petitioner, on the other hand, alleged that the portion of the subject property consisting of about 700 square meters was bought by Diosdado Herrera, Alfredos father, from a certain Domingo Villaran. Upon the death of Diosdado Herrera, Alfredo inherited the 700-square-meter lot. The COSLAP, in a Resolution dated December 6, 1999, ruled that respondents have a rightful claim over the subject property. Aggrieved petitioner Celia Vda. De Herrera filed a petition for certiorari with the CA. The CA ruled that the COSLAP has exclusive jurisdiction over the present case and, even assuming that the COSLAP has no jurisdiction over the land dispute of the parties herein, petitioner is already estopped from raising the issue of lack of jurisdiction before the COSLAP and he actively participated in the proceedings before the said body. Petitioner averred that the COSLAP has no adjudicatory powers to settle and decide the question of ownership over the subject land. Petitioner submits that it is the Regional Trial Court which has jurisdiction over controversies relative to ownership of the subject property. Respondents, on the other hand, alleged that the COSLAP has jurisdiction since Alfredos filing of the Motion for Reconsideration and/or Reopening of the proceedings before the COSLAP is indicative of his conformity with the questioned resolution of the COSLAP. Issue: Whether or not the COSLAP has jurisdiction to decide the question of ownership between the parties. Ruling: The petition is meritorious. Section 3 of Executive Order No. 561 creating COSLAP specifically enumerates the instances when COSLAP can exercise its adjudicatory functions. Administrative agencies like the COSLAP, are tribunals of limited jurisdiction that can only wield powers which are specifically granted to it by its enabling statute. Under Sec 3 of EO No. 561, the COSLAP has two options in acting on a land dispute or problem lodged before it, to wit: (a) refer the matter to the agency having appropriate jurisdiction for settlement/resolution; or (b) assume jurisdiction if the matter is one of those enumerated in paragraph 2 (a) to (e) of the law, if such case is critical and explosive in nature, taking into account the large number of parties involved, the presence or emergence of social unrest, or other similar critical situations requiring immediate action. In the instant case, the COSLAP has no jurisdiction over the subject matter of respondents complaint. The present case does not fall under any of the cases enumerated under Section 3,

paragraph 2 (a) to (e) of EO No. 561. The dispute between the parties can hardly be characterized as involving a critical situation that requires immediate action. Respondents allegation that petitioner is estopped from questioning jurisdiction of the COSLAP by reason of laches does not hold water. Petitioner is not estopped from raising the jurisdictional issue, because it may be raised at any stage of the proceedings, even on appeal and is not lost by waiver or by estoppel. The fact that a person attempts to invoke unauthorized jurisdiction of a court does not estop him from thereafter, challenging its jurisdiction over the subject matter, since such jurisdiction must arise by law and not by mere consent of the parties.