FACTS:

Petitioner Felipe Madriñan and respondent Francisca Madriñan were married and had four children. After a bitter quarrel, petitioner allegedly left their conjugal home and took their three sons with him to Albay and subsequently to Laguna. Respondent filed a petition for habeas corpus to have their three sons returned to her custody. Petitioner challenged the jurisdiction of the Court of Appeals and invoked the exclusive jurisdiction of family courts under RA 8369.

ISSUES:

1. Whether the Court of Appeals has jurisdiction over the petition for habeas corpus.

2. Whether family courts have exclusive jurisdiction over habeas corpus cases involving the custody of minors.

RULING:

1. The Court of Appeals had jurisdiction over the petition for habeas corpus. Under RA 8369, the Court of Appeals and the Supreme Court have concurrent jurisdiction with family courts in habeas corpus cases involving the custody of minors. This was further affirmed by A.M. No. 03-03-04-SC, which settled any uncertainty on the matter. The exclusive jurisdiction of family courts under RA 8369 pertains to custody cases, not habeas corpus cases. The writ of habeas corpus is merely ancillary to the custody case and should be issued by the same court to avoid conflicting decisions and judicial instability.

PRINCIPLES:

• Once a court acquires jurisdiction over a case, it has jurisdiction to the exclusion of all other courts, including related incidents and ancillary matters.

• Family courts have concurrent jurisdiction with the Court of Appeals and Supreme Court in habeas corpus cases where the custody of minors is involved.