GR 117383; (March, 1995) (Digest)
G.R. No. 117383 March 6, 1995
RIZAL COMMERCIAL BANKING CORPORATION (RCBC), petitioner, vs. HON. LUCIA V. ISNANI, PRESIDING JUDGE OF BRANCH 59, RTC, MAKATI, HON. FELICIDAD Y. NAVARRO-QUIAMBAO, PRESIDING JUDGE, BRANCH 65, MTC, MAKATI, AND LOLITA ENCELAN, respondents.
FACTS
Private respondent Lolita Encelan filed a complaint on April 27, 1994, with the Makati Regional Trial Court (RTC) to recover from petitioner Rizal Commercial Banking Corporation actual damages of $5,000.00 or its Philippine peso equivalent of approximately P137,675.00. Petitioner moved to dismiss the case for lack of jurisdiction, arguing that the complaint, with a principal demand not exceeding P200,000.00, was cognizable by the Metropolitan Trial Court (MTC) of Metro Manila under the newly effective Republic Act No. 7691. Instead of dismissing the complaint, respondent RTC Judge Lucia V. Isnani transferred the entire records of the case to the Metropolitan Trial Court on July 8, 1994. The case was assigned to MTC Judge Felicidad Navarro-Quiambao. Petitioner sought reconsideration of the transfer with the MTC, but respondent MTC Judge Navarro-Quiambao denied the motion on September 16, 1994. Hence, this petition.
ISSUE
Whether the Regional Trial Court correctly transferred the case to the Metropolitan Trial Court instead of dismissing it for lack of jurisdiction, given that the complaint was filed after the effectivity of Republic Act No. 7691 and the principal demand was within the exclusive original jurisdiction of the MTC.
RULING
The Supreme Court granted the motion for reconsideration and set aside the orders of the RTC and MTC judges. The Court ruled that under Republic Act No. 7691, which took effect on April 15, 1994, metropolitan and municipal trial courts have exclusive original jurisdiction over civil actions where the amount of the demand does not exceed P200,000.00 in Metro Manila, exclusive of interest, damages, attorney’s fees, litigation expenses, and costs. Since the complaint was filed on April 27, 1994, after the effectivity of R.A. No. 7691, and the principal demand was only approximately P137,675.00, the case fell within the exclusive jurisdiction of the Metro Manila MTC. The RTC judge should have dismissed the case for lack of jurisdiction instead of transferring it. The complaint in RTC Civil Case No. 94-1633 was ordered dismissed without prejudice to the filing of an original action with the court of proper jurisdiction.