Parcon vs. Court of Appeals

When an amended complaint introducing additional defendants is filed after the effectivity of Batas Pambansa Bilang 129, the original pleading is deemed abandoned and jurisdiction is determined by the date of the amended complaint, thereby placing an action for annulment of an RTC judgment within the exclusive original jurisdiction of the Court of Appeals.

Petitioner Manuel P. Parcon sought the annulment of a decision rendered by the then Court of First Instance of Manila, Branch XXX, in Civil Case No. 116500, a case involving Producers Bank of the Philippines. Batas Pambansa Bilang 129, which took effect on January 18, 1983, reorganized the judiciary and transferred jurisdiction over actions for annulment of Regional Trial Court judgments from the CFI/RTC to the Court of Appeals, vesting the latter with exclusive original jurisdiction over such proceedings.

On November 9, 1982, Manuel P. Parcon filed a complaint with the RTC of Iloilo, Branch XXXI, docketed as Civil Case No. 14708, seeking the annulment of the decision dated October 28, 1980 of the then Court of First Instance of Manila, Branch XXX, in Civil Case No. 116500. The defendants named in the original complaint were Producers Bank of the Philippines, the City Sheriff of Manila, and the Branch Sheriff of the CFI of Manila, Branch XXX.

On September 11, 1984, Parcon filed an amended complaint impleading Jessie R. Billena and Alfredo T. Javellana, together with the Intestate Estate of Federico Salvador and Gregorio Hechanova, as additional defendants. The RTC of Iloilo subsequently dismissed the amended complaint as against the estate in view of the commencement of administration proceedings therefor.

On March 2, 1987, private respondents Billena and Javellana filed a motion to dismiss, anchored on the ground that the RTC of Iloilo no longer had jurisdiction over the case because at the time the amended complaint was filed, jurisdiction over actions for annulment of judgments of Regional Trial Courts had already been vested in the Court of Appeals under Batas Pambansa Bilang 129. The RTC of Iloilo denied the motion to dismiss. On appeal, the Court of Appeals reversed, declaring the RTC's order of December 28, 1987 null and void and ordering the dismissal of Civil Case No. 14708 for lack of jurisdiction, with the directive that the plaintiff bring the complaint to the proper tribunal in accordance with BP 129.

• Lack of Jurisdiction: Private respondents argued that the RTC of Iloilo no longer had jurisdiction over the case because at the time the amended complaint was filed, BP 129 had already taken effect and vested exclusive original jurisdiction over actions for annulment of RTC judgments in the Court of Appeals.

• Jurisdiction: Whether the RTC of Iloilo can continue to exercise jurisdiction over an action for annulment of a CFI decision after the plaintiff amended the complaint at a time when Batas Pambansa Bilang 129 was already in effect.

• Jurisdiction: No. The RTC of Iloilo could not continue exercising jurisdiction because the amended complaint, filed after BP 129's effectivity on January 18, 1983, was deemed to have abandoned the original pleading, placing the case under the Court of Appeals' exclusive original jurisdiction pursuant to Section 9(2) of BP 129.

• Jurisdiction: Batas Pambansa Bilang 129, which took effect on January 18, 1983, divested the CFI (now RTC) of jurisdiction over actions for annulment of RTC judgments and vested exclusive original jurisdiction in the Court of Appeals under Section 9(2). The original complaint was filed on November 9, 1982, before BP 129's effectivity. However, the amended complaint was filed on September 11, 1984, after BP 129 had already taken effect. When a pleading is amended to introduce a new cause of action or additional defendants, the original pleading is deemed abandoned and the case stands for trial on the amended complaint only, following Insular Veneer, Inc. vs. Plan. Because the amended complaint was filed after BP 129's effectivity, the action fell under the exclusive original jurisdiction of the Court of Appeals. Exclusive jurisdiction precludes the idea of co-existence and refers to jurisdiction possessed to the exclusion of others, as held in Ong vs. Parel. Accordingly, the RTC of Iloilo could not continue exercising jurisdiction over Civil Case No. 14708.

• Abandonment of Original Pleading by Amendment — When a pleading is amended, particularly one that introduces a new cause of action or includes additional defendants, the original pleading is deemed abandoned and the case stands for trial on the amended complaint only. Applied here to determine that jurisdiction should be assessed based on the date of the amended complaint, not the original, thereby placing the action under the Court of Appeals' jurisdiction.

• Exclusive Jurisdiction — Exclusive jurisdiction precludes the idea of co-existence and refers to jurisdiction possessed to the exclusion of others. Applied to hold that once BP 129 vested exclusive original jurisdiction over annulment of RTC judgments in the Court of Appeals, the RTC could no longer exercise concurrent jurisdiction over such actions.

• "When a pleading is amended which introduces a new cause of action or includes additional defendants, the original pleading is deemed abandoned and the case now stands for trial on the amended complaint only." — This is the ratio decidendi, explaining why jurisdiction is determined by the date of the amended complaint rather than the original filing.

• "Exclusive jurisdiction precludes the Idea of co-existence and refers to jurisdiction possessed to the exclusion of others." — Defines the nature of exclusive jurisdiction, supporting the conclusion that the RTC could not concurrently exercise jurisdiction once the Court of Appeals was vested with exclusive original jurisdiction.

• Insular Veneer, Inc. vs. Plan, 73 SCRA 9 — Followed. Cited for the rule that an amended pleading introducing new causes of action or additional defendants abandons the original pleading, so that the case stands on the amended complaint alone.

• Ong vs. Parel, 156 SCRA 768 — Followed. Cited for the definition of exclusive jurisdiction as precluding co-existence and referring to jurisdiction possessed to the exclusion of others.

• Section 9(2), Batas Pambansa Bilang 129 — Vests exclusive original jurisdiction over actions for annulment of judgments of Regional Trial Courts in the Court of Appeals (then Intermediate Appellate Court). Applied to divest the RTC of Iloilo of jurisdiction over the annulment action, since the amended complaint was filed after the law's effectivity.

• Section 44, Batas Pambansa Bilang 129 — Provides for the transition of cases pending in the old courts to the appropriate courts constituted under the Act, together with pertinent functions, records, equipment, property, and necessary personnel. Cited in the Court of Appeals' decision as part of the statutory framework for the judiciary reorganization.

Melencio-Herrera (Chairman), Padilla, Sarmiento, and Regalado, JJ., concur.