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ATTY. JESUS F. FERNANDEZ v. CA

FACTS:

Concepcion Olivares filed a complaint for unlawful detainer against Jesus Fernandez. The Metropolitan Trial Court (MeTC) dismissed the complaint due to lack of sufficient cause of action. Olivares appealed the decision to the Regional Trial Court (RTC), which reversed the MeTC's ruling and ordered Fernandez to pay rental arrearages and other expenses. Fernandez filed a Motion for Reconsideration, which was denied. He then filed a Motion for Extension of Time to File Petition for Review in the Court of Appeals and a Motion for New Trial in the RTC based on newly discovered evidence. Fernandez also sought to withdraw his Petition for Review in the Court of Appeals. The RTC denied the Motion for New Trial, and it was upheld by the Court of Appeals. Fernandez filed a Motion for Reconsideration, which was denied. He subsequently filed a Petition for Certiorari with the Court of Appeals, which temporarily halted the enforcement of the writ of execution. However, the Court of Appeals eventually denied the Petition. Fernandez filed another Motion for Reconsideration, which was denied as well. The main issue to be resolved is whether the filing of a Motion for Extension of Time to File Petition for Review deprived the RTC of its jurisdiction to entertain the Motion for New Trial.

ISSUES:

  1. Whether or not the mere filing of a Motion for Extension of Time to File Petition for Review automatically divested the Regional Trial Court (RTC) of its jurisdiction over the case to entertain a Motion for New Trial.

RULING:

  1. The Court ruled that the mere filing of a Motion for Extension of Time to File Petition for Review does not automatically divest the Regional Trial Court (RTC) of its jurisdiction over the case to entertain a Motion for New Trial. In order for a Court to have authority to dispose of the case on the merits, it must acquire jurisdiction over the subject matter and over the parties. Jurisdiction over the subject matter, or the jurisdiction to hear and decide a case, is conferred by law. Jurisdiction over the person, on the other hand, is acquired by service of summons or by voluntary appearance. The filing of motions seeking affirmative relief, such as a Motion for Extension of Time to File Petition for Review, is considered voluntary submission to the jurisdiction of the court. However, the Rules of Court require specific conditions for jurisdiction to attach in an appellate court, including the timely invocation of the court's jurisdiction, timely filing of the petition for review, payment of docket fees, and perfection of appeals by other parties in due time.

PRINCIPLES:

  • The court must acquire jurisdiction over the subject matter and over the parties in order to dispose of a case on the merits.

  • Jurisdiction over the subject matter is conferred by law.

  • Jurisdiction over the person is acquired by service of summons or voluntary submission to the court's jurisdiction.

  • The filing of motions seeking affirmative relief is considered voluntary submission to the court's jurisdiction.

  • For jurisdiction to attach in an appellate court, additional conditions must be met, including timely invocation of the court's jurisdiction, timely filing of the petition for review, payment of docket fees, and perfection of appeals by other parties in due time.