G.R. No. L-77869 March 16, 1988
EMILIO ENRIQUEZ, plaintiff-appellee, vs. FORTUNA MARI CULTURE CORPORATION, defendant-appellant.

FACTS

Plaintiff Emilio Enriquez filed a complaint for sum of money on January 31, 1983, with the Regional Trial Court (RTC) of Zamboanga City, seeking to recover P17,483.61 (principal plus interest). The defendant corporation was declared in default, and the RTC rendered a judgment in favor of the plaintiff. The defendant appealed to the Court of Appeals, contesting the RTC’s jurisdiction. The defendant argued that under Batas Pambansa Blg. 129 (the Judiciary Reorganization Act of 1981), which reallocated jurisdictional amounts, exclusive original jurisdiction over cases where the demand does not exceed P20,000 (exclusive of interest and costs) was vested in Municipal Trial Courts (MTCs). Since the principal claim was only P15,336.50, jurisdiction allegedly belonged to the MTC, not the RTC.
The trial court justified its assumption of jurisdiction by citing a Supreme Court en banc Resolution dated February 14, 1983. This Resolution provided guidelines for the distribution of cases during the transition to the new judiciary structure. It stated that all cases pending in the RTCs as of February 14, 1983, would remain with the RTCs, even if the amount involved would, under BP 129, fall within the new jurisdiction of the lower courts. The plaintiff’s case was filed on January 31, 1983, and was therefore pending before the RTC on the cutoff date. The defendant corporation assailed this application, arguing that the Supreme Court Resolution effectively amended BP 129, violating the principle of separation of powers by legislating from the bench.

ISSUE

Whether the Supreme Court’s February 14, 1983, en banc Resolution, which allowed pending cases in the RTC to remain there despite a change in jurisdictional amounts under BP 129, constituted an unconstitutional amendment of the statute and a violation of the separation of powers.

RULING

The Supreme Court ruled that the Resolution did not amend BP 129 and did not violate the separation of powers. The Court explained that BP 129’s effectivity was not self-executing. Section 44 of the law contained transitory provisions, stating that the Act’s provisions would be carried out pursuant to an Executive Order from the President, and the old courts would continue to function until the President declared the reorganization complete. The Supreme Court, exercising its constitutional power to promulgate rules concerning pleading, practice, and procedure, issued the February 14, 1983, Resolution to provide necessary guidelines for the orderly transfer and distribution of cases during the transitional period. This was an administrative implementation, not a substantive legislative amendment.
The Court clarified that there was a phased implementation of BP 129, requiring sequential action by the Executive (to declare the reorganization complete) and the Judiciary (to issue rules for case distribution). The Resolution merely operationalized the statute’s transitory provisions by setting a specific cutoff date (February 14, 1983) to determine which court would retain pending cases. It did not alter the substantive jurisdictional thresholds established by BP 129 for cases filed after that date. Therefore, the RTC correctly retained jurisdiction over the case filed before the cutoff date, and the Supreme Court’s action was a valid exercise of its rule-making authority, consistent with the separation of powers. The trial court’s decision was affirmed.