SEBASTIAN VS NG

Amicable Settlement; An amicable settlement or arbitration award that is not repudiated within a period
of ten (10) days from the settlement may be enforced by: first, execution by the Lupon within six (6)
months from the date of the settlement; or second, by an action in the appropriate city or municipal trial
court (MTC) if more than six (6) months from the date of settlement has already elapsed.—A simple
reading of Section 417 of the Local Government Code readily discloses the two-tiered mode of
enforcement of an amicable settlement. The provision reads: Section 417. Execution.—The amicable
settlement or arbitration award may be enforced by execution by the lupon within six (6) months from the
date of the settlement. After the lapse of such time, the settlement may be enforced by action in the
appropriate city or municipal court. [Emphasis ours] Under this provision, an amicable settlement or
arbitration award that is not repudiated within a period of ten (10) days from the settlement may be
enforced by: first, execution by the Lupon within six (6) months from the date of the settlement; or
second, by an action in the appropriate city or municipal trial court if more than six (6) months from the
date of settlement has already elapsed.

Same; Under Section 416 of the Local Government Code (LGC), the amicable settlement and arbitration
award shall have the force and effect of a final judgment of a court upon the expiration of ten (10) days
from the date of its execution, unless the settlement or award has been repudiated or a petition to nullify
the award has been filed before the proper city or municipal court.— Under Section 416 of the Local
Government Code, the amicable settlement and arbitration award shall have the force and effect of a final
judgment of a court upon the expiration of ten (10) days from the date of its execution, unless the
settlement or award has been repudiated or a petition to nullify the award has been filed before the
proper city or municipal court. Moreover, Section 14, Rule VI of the Katarungang Pambarangay
Implementing Rules states that the party’s failure to repudiate the settlement within the period of ten (10)
days shall be deemed a waiver of the right to challenge the settlement on the ground that his/her consent
was vitiated by fraud, violence or intimidation.

FACTS:

Michael Sebastian and Annabel Lagmay Ng were sweethearts. While Annabel was working in Hongkong,
she sent Michael the amount of P350,000.00 to purchase a truck, as their investment. However, after
Annabel and Michael’s relationship had ended, Michael allegedly refused to return the money to Annabel,
prompting the latter to bring the matter before the Barangay Justice.

Angelita, acting as representative and attorney-in-fact of her daughter Annabel, filed a complaint before
the Barangay Justice of Siclong, Laur, Nueva Ecija, seeking to collect from Michael Sebastian the sum of
P350,000.00 that Annabel sent to Michael.

On July 9, 1997, the parties entered into an amicable settlement, evidenced by a document denominated
as “kasunduan” wherein Michael agreed to pay Annabel the amount of P250,000.00 on specific dates. The
kasunduan was signed by Angelita (on behalf of Annabel), Michael, and the members of the pangkat ng
tagapagkasundo.

After about one and a half years from the date of the execution of the kasunduan, Angelita filed with the
MCTC a Motion for Execution of the kasunduan.

The MCTC rendered a decision in favor of Annabel. On appeal, the RTC upheld the MCTC decision. Michael
filed a Motion for Reconsideration arguing, among others, that the MCTC does not have jurisdiction over
the case since the amount of P250,000.00 (as the subject matter of the kasunduan) is in excess of MCTC’s
jurisdictional amount of P200,000.00. The RTC granted Michael’s MR, and ruled that there is merit in the
jurisdictional issue he raised. It dismissed Angelita’s Motion for Execution, and set aside the MCTC
Decision. Angelita subsequently filed a Petition for Review with the CA. The CA granted the petition, and
reversed the RTC’s decision.

Michael’s MR was denied, hence, this petition.

ISSUES:

Whether or not the MCTC has the authority and jurisdiction to execute the kasunduan regardless of the
amount involved.

Whether the kasunduan has the force and effect of a final judgment.

RULING:

The MCTC has the authority and jurisdiction to enforce the kasunduan regardless of the amount involved.
The Court finds that the CA correctly upheld the MCTC’s jurisdiction to enforce any settlement or
arbitration award issued by the Lupon. We again draw attention to the provision of Section 417 of the
Local Government Code that after the lapse of the six (6) month period from the date of the settlement,
the agreement may be enforced by action in the appropriate city or municipal court. The law, as written,
unequivocally speaks of the “appropriate city or municipal court” as the forum for the execution of the
settlement or arbitration award issued by the Lupon. Notably, in expressly conferring authority over these
courts, Section 417 made no distinction with respect to the amount involved or the nature of the issue
involved. Thus, there can be no question that the law’s intendment was to grant jurisdiction over the
enforcement of settlement/arbitration awards to the city or municipal courts regardless of the amount. A
basic principle of interpretation is that words must be given their literal meaning and applied without
attempted interpretation where the words of a statute are clear, plain and free from ambiguity.

The kasunduan has the force and effect of a final judgment. Under Section 416 of the Local Government
Code, the amicable settlement and arbitration award shall have the force and effect of a final judgment of
a court upon the expiration often (10) days from the date of its execution, unless the settlement or award
has been repudiated or a petition to nullify the award has been filed before the proper city or municipal
court. Moreover, Section 14, Rule VI of the Katarungang Pambarangay Implementing Rules states that the
party’s failure to repudiate the settlement within the period often (10) days shall be deemed a waiver of
the right to challenge the settlement on the ground that his/her consent was vitiated by fraud, violence or
intimidation. In the present case, the records reveal that Michael never repudiated the kasunduan within
the period prescribed by the law. Hence, the CA correctly ruled that the kasunduan has the force and
effect of a final judgment that is ripe for execution.

Genesis Investment Inc. v. Heirs of Ebarasabal

Civil Procedure; Jurisdiction; Actions; In determining whether an action is one the subject matter of which
is not capable of pecuniary estimation, the Supreme Court has adopted the criterion of first ascertaining
the nature of the principal action or remedy sought.―Clearly, this is a case of joinder of causes of action
which comprehends more than the issue of partition of or recovery of shares or interest over the real
property in question but includes an action for declaration of nullity of contracts and documents which is
incapable of pecuniary estimation. As cited by the CA, this Court, in the case of Singsong v. Isabela Sawmill,
88 SCRA 623 (1979), held that: In determining whether an action is one the subject matter of which is not
capable of pecuniary estimation, this Court has adopted the criterion of first ascertaining the nature of the
principal action or remedy sought. If it is primarily for the recovery of a sum of money, the claim is
considered capable of pecuniary estimation, and whether jurisdiction is in the municipal courts or in the
courts of first instance would depend on the amount of the claim. However, where the basic issue is
something other than the right to recover a sum of money, where the money claim is purely incidental to,
or a consequence of, the principal relief sought, this Court has considered such actions as cases where the
subject of the litigation may not be estimated in terms of money, and are cognizable by courts of first
instance [now Regional Trial Courts

FACTS:
Respondents filed a Complaint for “Declaration of Nullity of Documents, Recovery of Shares,
Partition, Damages and Attorney’s Fees” against herein petitioners.
Petitioners filed a Motion to Dismiss contending, among others, that the RTC has no jurisdiction
to try the case on the ground that, as the case involves title to or possession of real property or
any interest therein and since the assessed value of the subject property does not exceed
P20,000.00 (the same being only P11,990.00), the action falls within the jurisdiction of the MTC.
The RTC granted petitioners’ Motion to Dismiss.
Respondents filed a Motion for Partial Reconsideration, arguing that their complaint consists of
several causes of action, including one for annulment of documents, which is incapable of
pecuniary estimation and, as such, falls within the jurisdiction of the RTC.
The RTC issued an Order granting respondents’ Motion for Partial Reconsideration and reversing
its earlier Order.
After their Motion for Reconsideration was denied, petitioners filed a petition for certiorari with
the CA.
However, the CA dismissed the petition, holding that the subject matter of respondents’
complaint is incapable of pecuniary estimation and, therefore, within the jurisdiction of the RTC,
considering that the main purpose in filing the action is to declare null and void the documents
assailed therein. Petitioners’ Motion for Reconsideration was, subsequently, denied by the CA.
Hence, the instant petition for review on certiorari.

ISSUE:
Whether the RTC has jurisdiction over the case where the allegations in the complaint shows that
the main cause of action is for the Recovery of their Title, Interest, and Share over a Parcel of
Land, which has an assessed value of P11,990.00.
RULING:
The petition lacks merit. It is true that one of the causes of action of respondents pertains to the
title, possession and interest of each of the contending parties over the contested property, the
assessed value of which falls within the jurisdiction of the MTC. However, a complete reading of
the complaint would readily show that, based on the nature of the suit, the allegations therein,
and the reliefs prayed for, the action is within the jurisdiction of the RTC.
It is clear from the records that respondents’ complaint was for “Declaration of Nullity of
Documents, Recovery of Shares, Partition, Damages and Attorney’s Fees.”
In filing their Complaint with the RTC, respondents sought to recover ownership and possession
of their shares in the disputed parcel of land by questioning the due execution and validity of the
Deed of Extrajudicial Settlement with Sale as well as the Memorandum of Agreement entered
into by and between some of their co-heirs and herein petitioners.
Aside from praying that the RTC render judgment declaring as null and void the said Deed of
Extrajudicial Settlement with Sale and Memorandum of Agreement, respondents likewise sought
the following:

(1) nullification of the Tax Declarations subsequently issued in the name of petitioner Cebu Jaya
Realty, Inc.;
(2) partition of the property in litigation;
(3) reconveyance of their respective shares; and
(4) payment of moral and exemplary damages, as well as attorney’s fees, plus appearance fees.
Clearly, this is a case of joinder of causes of action which comprehends more than the issue of
partition of or recovery of shares or interest over the real property in question but includes an
action for declaration of nullity of contracts and documents which is incapable of pecuniary
estimation.
Since the principal action sought in respondents’ Complaint is something other than the recovery
of a sum of money, the action is incapable of pecuniary estimation and, thus, cognizable by the
RTC.
Well entrenched is the rule 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 party is entitled to all or some of the claims asserted.
Moreover, it is provided under Section 5 (c), Rule 2 of the Rules of Court that where the causes of
action are between the same parties but pertain to different venues or jurisdictions, the joinder
may be allowed in the RTC provided one of the causes of action falls within the jurisdiction of said
court and the venue lies therein.
Thus, as shown above, respondents’ complaint clearly falls within the jurisdiction of the RTC.

Daichi Electronics Manufacturing v. Villarama

Jurisdiction; Damages; Action to recover damages agreed upon in the contract is within the realm of Civil
Law, and jurisdiction over the controversy belongs to the regular courts.— Petitioner does not ask for any
relief under the Labor Code of the Philippines. It seeks to recover damages agreed upon in the contract as
redress for private respondent’s breach of his contractual obligation to its “damage and prejudice” (Rollo,
p. 57). Such cause of action is within the realm of Civil Law, and jurisdiction over the controversy belongs
to the regular courts. More so when we consider that the stipulation refers to the postemployment
relations of the parties.

Money claims of workers which now fall within the original and exclusive jurisdiction of Labor Arbiters are
those money claims which have some reasonable causal connection with the employer-employee
relationship.—The Court, therefore, believes and so holds that the ‘money claims of workers’ referred to
in paragraph 3 of Article 217 embraces money claims which arise out of or in connection with the
employer-employee relationship or some aspect or incident of some relationship. Put a little differently,
that money claims of workers which now fall within the original and exclusive jurisdiction of Labor Arbiters
are those money claims which have some reasonable causal connection with the employer-employee
relationship.”

When the cause of action is based on a quasidelict or tort, which has no reasonable causal connection with
any of the claims provided for in Article 217, jurisdiction over the action is with the regular courts.—San
Miguel was cited in Ocheda v. Court of Appeals, 214 SCRA 629 (1992), where we held that when the cause
of action is based on a quasi-delict or tort, which has no reasonable causal connection with any of the
claims provided for in Article 217, jurisdiction over the action is with the regular courts.

FACTS:

On July 29, 1993, the petitioner Daichi electronics filed a complaint for damages with RTC branch
156 for an employee’s (Limjuco) violation of their contract in 1990 which stipulated that the
termination of service of an employee restricted him from working in a company which has a
similar set of products or ventures for a span of 2 years following the termination of service.
The petitioner claimed that respondent became an employee of such a company called Angel
Sound with the same position as head of material management control before the 2 years was
up. The petitioner sought to claim 100k in damages and prevent the former employee from
working in the rival business within the 1 year timespan.
The respondent court claimed that it had no jurisdiction because the complaint was for damages
from labor-employee relations and should be adjudicated under the Labor Arbiter under Art 217 s
4 of the LC. The petitioner asked for reversal because the case was recognizable under the regular
courts and that the cause of action didn’t arise from employee-employer relationships even if the
claim was in the employee’s contract.

ISSUE:
Is the petitioner’s claim for damages one arising from employee-employer relations?

RULING:
No, petition granted. Art 217 s 4 of the LC stipulated that Labor Arbiters have exclusive
jurisdiction to hear and decide cases for workers with claims for actual, moral, exemplary and
other forms of damages arising from employer-employee relations.
The court held that the cause of action was under Civil Law, not the labor code. The petitioner
sought to recover damages agreed upon in the contract as redress for respondent’s breach of his
contractual obligation to its damage and prejudice. He also didn’t ask for relief under the Labor
Code. The applicable case law was Singapore airlines v Pano where the employer’s claim for
damages was based on wanton failure and refusal without just cause to report to duty coupled
with the averment that the employee maliciously and with bad faith violated the contract. The
employee didn’t report for duty as a course of convention training- quasi-delict.
There must be a causal connection for claims provided in the RT 217 S4 OF THE LC. Only when
there is such a connection with other claims can damages be considered as arising from
employer-employee relations.
In SMC v NLRC, the interpretation of Art 217 then was focused on in the phrase “all money claims
of workers” in par 3.
There was no phrase “arising from employer-employee relations at that time”.

Eugenio vs. Sta. Monica Riverside Homeowners Association

Jurisdiction.—Upon conferment of quasi-judicial functions to an administrative agency, all controversies
relating to the subject matter which pertain to its specialization are deemed included within its
jurisdiction. Since the HLURB is vested by law with jurisdiction to regulate and supervise homeowner
associations, respondent correctly lodged their complaint with the HLURB.

Same.—The case is within the competence of HLURB to decide. While the SHFC is the main government
agency tasked to administer the CMP, its authority pertains only to the administrative and financing
aspects of the State’s social housing program schemes, i.e., evaluation of the community association and
originator based on the submitted documents, site inspection, releasing of funds for land acquisition, site
development and housing assistance, collection of monthly amortizations from community associations
and foreclosure of mortgages.

FACTS:
The residents of a parcel of land owned by Hi-Marketing Corporation situated in Quezon City,
organized themselves into a community association, the Sta. Monica Riverside Homeowners
Association (respondent). It registered with the HLURB for the purpose of acquiring land under
the Community Mortgage Program (CMP) of the Social Housing Finance Corporation (SHFC).
When respondent commenced negotiations with Hi-Marketing Corporation for purchase of the
land, it invited Edna Eugenio, Mary Jean Gregorio, Renato Pajarillo and Rogelio Villamor
(petitioners) who are occupying a portion of the land to become its members (respondents) but
that they refused, having formed another organization which was not accredited, however, by the
HLURB for lack of a Memorandum of Agreement with Hi-Marketing Corporation.
Since only members of an association are allowed to avail of the benefits under the CMP,
respondent invited petitioners anew to join but petitioners declined, prompting respondent to
issue a formal demand for petitioners to leave their respective premises.
Petitioners ignored respondents demand to leave, hence, respondent filed a complaint for
ejectment/eviction against them before the HLURB. Petitioners denied refusing to join the
association. They questioned respondents membership as composed of non-residents which is
contrary to the CMP guidelines. They also questioned the leadership, and alleged illegal activities
of respondents president Erlinda Manalo, as well as the propriety of HLURB's cognizance of the
complaint and prayed for its dismissal for lack of jurisdiction.
Housing and Land Use Arbiter Joselito F. Melchor ordered petitioners exclusion from the benefits
of the CMP and consequently to surrender them and vacate the premises. On appeal, the Board
of Commissioners affirmed the Arbiters Decision. Petitioners elevated the case to the Office of the
President which also affirmed the decision.
Petitioners appealed to the CA but the same was denied for lack of merit. Upon denial of their
motion for reconsideration, the present petition is filed.
Petitioners argue that the HLURB does not have jurisdiction over the case as it does not fall under
the category of an intra-corporate controversy, their being non-members having been established
and acknowledged by respondent. Likewise, they argue that the case cannot be deemed a
controversy between the association and the general public since the main issue does not pertain
to respondents juridical personality.
Petitioners add that Batas Pambansa Blg. 129,as amended, vests exclusive jurisdiction over cases
of forcible entry and unlawful detainer on first level courts.

ISSUE: Whether or not HLURB has jurisdiction

RULING: Yes. CA Decision Affirmed. Upon conferment of quasi-judicial functions to an

administrative agency, all controversies relating to the subject matter which pertain to its
specialization are deemed included within its jurisdiction
Since the HLURB is vested by law with jurisdiction to regulate and supervise homeowner
associations, respondent correctly lodged their complaint with the HLURB. Republic Act No. 8763
provides:
Section 26. Powers over Homeowners Associations. The powers authorities and responsibilities
vested in the Corporation (formerly Home Insurance Guaranty Corporation) with respect to
homeowners association under Republic Act No. 580, as amended by executive Order No. 535 is
hereby transferred to the Housing and Land use Regulatory Board (HLURB).
Petitioners in fact, in their reply to the complaint, acknowledged the HLURB's jurisdiction when
they challenged respondent's right to exist as a corporate entity,viz:
(5) That complainants statements from number 6-12 in reference to that of the respondents are
already terminated and non members and non program beneficiaries of the CMP would not hold
water. At this point, respondent in this instance, would like to emphasize that they are not
opposing the implementation of the Community Mortgage Program. They are only questioning
the legitimacy and the illegal activities of Erlinda Manalo.
If petitioners refuse to recognize respondents legitimacy, respondent will not be able to fulfill its
obligation to collect and account for the monthly amortizations with SHFC. Individual titling would
not thus be completed and the laudable objectives of the CMP would not be fully attained.
Undoubtedly, the case is within the competence of HLURB to decide. While the SHFC is the main
government agency tasked to administer the CMP, its authority pertains only to the
administrative and financing aspects of the States social housing program schemes,i.e.,evaluation
of the community association and originator based on the submitted documents, site inspection,
releasing of funds for land acquisition, site development and housing assistance, collection of
monthly amortizations from community associations and foreclosure of mortgages.
While a complaint for ejectment, which raises the issue of who has a better right of possession,
falls within the exclusive and original jurisdiction of first level courts, the right of possession in the
present case is, however, necessarily intertwined with a determination of rights and privileges
under a distinctive social housing concept such as CMP, which falls within the expertise of the
HLURB.

BDO Unibank, Inc. v. Sunnyside Heights Homeowner’s Association, Inc.

FACTS:
Mover Enterprises, Inc. (Mover) is the owner and developer of the Sunnyside Heights
Subdivision located in Batasan Hills, Quezon City. Mover mortgaged portion of the said
subdivision to the Philippine Commercial International Bank (PCIB) to secure a loan of
P1,700,000.00. Mover failed to pay its loan and PCIB foreclosed on the mortgage.
Later, PCIB advertised the aforesaid lot for sale in the newspapers. This prompted the Sunnyside Heights
Homeowners Association (SHHA) to file before the Housing and Land Use Regulatory Board (HLURB) a
letter-complaint.

Letter-complaint filed by SHHA in HLURB to declare the mortgage between Mover and PCIB void on the
ground that the subject property has been allocated as SHHA's open space pursuant to law
On its answer, PCIB stated that the mortgaged lot is different from the lot referred to in SHHA's complaint.
The title to the said mortgaged lot bears no annotation that it has been reserved as open space and under
BP 129 and PD 1344, complaint should’ve been filed with regular courts

HLURB dismissed SHHA complaint for lack of cause of action. No proof that object is the same property
under Mover’s titles. SSHA now filed Petition for Review to the HLURB Board of Commissioners.
This petition was appealed to the Office of the President. The Office of the President ruled that the HLURB
has jurisdiction over matters related to or connected with the complaint for annulment of mortgage, as in
this case. Meanwhile, PCIB merged with Equitable Banking Corporation to become the Equitable PCI Bank.
Then it merged with Banco de Oro Universal Bank and became the Banco de Oro-EPCI, Inc.; now it is
known as Banco de Oro Unibank, Inc. (BDO). On its appeal to the CA it argued that HLURB has no
jurisdiction over the case but was denied by the CA. CA stated that HLURB has jurisdiction to regulate the
real estate trade is broad enough to include jurisdiction over complaints for annulment of mortgage."
The CA further noted Banco de Oro-EPCI, Inc.'s argument that Mover's obligation was more than the
principal amount of P1,700,000.00. Inasmuch as the amount represents a loan, Mover must also be held
liable for the payment of interest at the rate stipulated in the mortgage contract.

ISSUE:

WON HLURB has jurisdiction over the case?

RULING:

YES, HLURB has jurisdiction. Under Section 3 of P.D. No. 957[29] granted to the National Housing Authority
(NHA) exclusive jurisdiction to regulate the real estate trade and business in order to curb swindling and
fraudulent manipulations by unscrupulous subdivision and condominium sellers. P.D. No. 1344 in turn
expanded the jurisdiction of the NHA to hear and decide cases of the ff nature:
o a) Unsound real estate business practices;
o b) Claims involving refund and any other claims filed by subdivision lot or condominium
unit buyer against the project owner, developer, dealer, broker or salesman; and
o c) Cases involving specific performance of contractual and statutory obligations filed by
buyers of subdivision lot or condominium unit against the owner, developer, dealer,
broker or salesman.
Under Executive Order (E.O.) No. 648, which reorganized the Human Settlements Regulatory
Commission in 1981, the regulatory and quasi-judicial functions of the NHA were transferred to the
Human Settlements Regulatory Commission, later renamed as HLURB under E.O. No. 90.[3. In the cases
reaching this Court, the consistent ruling has been that the HLLJRB has jurisdiction over complaints
arising from contracts between the subdivision developer and the lot buyer, or those aimed at
compelling the developer to comply with its contractual and statutory obligations.