Sunday, October 16, 2022

CASE DIGEST : Municipality of Kananga v. Madrona

 G.R. No. 141375            April 30, 2003


MUNICIPALITY OF KANANGA, Represented by its Mayor, Hon. GIOVANNI M. NAPARI, petitioner,

vs.

Hon. FORTUNITO L. MADRONA, Presiding Judge, Regional Trial Court of Ormoc City (Branch 35); and the CITY OF ORMOC, Represented by its Mayor, Hon. EUFROCINO M. CODILLA SR., respondents.

FACTS: A boundary dispute arose between the Municipality of Kananga and the City of Ormoc. By agreement, the parties submitted the issue to amicable settlement by a joint session of the Sangguniang Panlungsod of Ormoc City and the Sangguniang Bayan of Kananga on October 31, 1997. No amicable settlement was reached. Instead, the members of the joint session issued Resolution No. 97-01. No amicable settlement was reached. Instead, the members of the joint session issued Resolution No. 97-01. In denying the Municipality of Kananga’s Motion to Dismiss, the RTC held that it had jurisdiction over the action under Batas Pambansa Blg. 129. Not satisfied with the denial of its Motion, the Municipality of Kananga filed this Petition. In their respective Memoranda, both parties raise the lone issue of whether respondent court may exercise original jurisdiction over the settlement of a boundary dispute between a municipality and an independent component city.

ISSUE: WON the RTC has jurisdiction

HELD: Jurisdiction is the right to act on a case or the power and the authority to hear and determine a cause.7 It is a question of law. As consistently ruled by this Court, jurisdiction over the subject matter is vested by law Because it is "a matter of substantive law, the established rule is that the statute in force at the time of the commencement of the action determines the jurisdiction of the court. Jurisdiction must exist as a matter of law and cannot be conferred by the consent of the parties or by estoppel. It should not be confused with venue. Since there is no law providing for the exclusive jurisdiction of any court or agency over the settlement of boundary disputes between a municipality and an independent component city of the same province, respondent court committed no grave abuse of discretion in denying the Motion to Dismiss. RTCs have general jurisdiction to adjudicate all controversies except those expressly withheld from their plenary powers. They have the power not only to take judicial cognizance of a case instituted for judicial action for the first time, but also to do so to the exclusion of all other courts at that stage. Indeed, the power is not only original, but also exclusive.


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