Effect of designation as special court

The designation of RTC Branch 149 as an Special Commercial Court does not diminish its power as a court of general jurisdiction to hear and decide cases of all nature, whether civil, criminal or special proceedings. (G.R. No. 203678, February 17, 2016)For further guidance, the Court finds it apt to point out that the same principles apply to the inverse situation of ordinary civil cases filed before the proper RTCs but wrongly raffled to its branches designated as Special Commercial Courts. In such a scenario, the ordinary civil case should then be referred to the Executive Judge for re-docketing as an ordinary civil case; thereafter, the Executive Judge should then order the raffling of the case to all branches of the same RTC, subject to limitations under existing internal rules, and the payment of the correct docket fees in case of any difference. Unlike the limited assignment/raffling of a commercial case only to branches designated as Special Commercial Courts in the scenarios stated above, the re-raffling of an ordinary civil case in this instance to all courts is permissible due to the fact that a particular branch which has been designated as a Special Commercial Court does not shed the RTCs general jurisdiction over ordinary civil cases under the imprimatur of statutory law, i.e., Batas Pambansa Bilang (BP 129). To restate, the designation of Special Commercial Courts was merely intended as a procedural tool to expedite the resolution of commercial cases in line with the court's exercise of jurisdiction. This designation was not made by statute but only by an internal Supreme Court rule under its authority to promulgate rules governing matters of procedure and its constitutional mandate to supervise the administration of all courts and the personnel thereof. Certainly, an internal rule promulgated by the Court cannot go beyond the commanding statute. But as a more fundamental reason, the designation of Special Commercial Courts is, to stress, merely an incident related to the court's exercise of jurisdiction, which, as first discussed, is distinct from the concept of jurisdiction over the subject matter. The RTCs general jurisdiction over ordinary civil cases is therefore not abdicated by an internal rule streamlining court procedure. (G.R. No. 203678, February 17, 2016)

It is apt to note, however, that the foregoing guideline applies only in a situation where the ordinary civil case filed before the proper RTCs was "wrongly raffled" to its branches designated as Special Commercial Courts, which situation does not obtain in this case. Here, no clear and convincing evidence is shown to overturn the legal presumption that official duty has been regularly performed when the Clerk of Court of the Makati RTC docketed the petition for injunction with damages as an ordinary civil case -not as a commercial case - and, consequently, raffled it among all branches of the same RTC, and eventually assigned it to Branch 149. To recall, the designation of the said branch as a Special Commercial Court by no means diminished its power as a court of general jurisdiction to hear and decide cases of all nature, whether civil, criminal or special proceedings. There is no question, therefore, that the Makati RTC, Branch 149 erred in dismissing the petition for injunction with damages, which is clearly an ordinary civil case. As a court of general jurisdiction, it still has jurisdiction over the subject matter thereof. (G.R. No. 203678, February 17, 2016)

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