Anama vs. Citibank, N.A. (formerly First National City Bank)

G.R. No. 192048. December 13, 2017.

FACTS

Douglas F. Anama obtained a loan and executed a promissory note in the amount of P418,000 and a chattel mortgage in favor of Citibank. Due to the failure of Anama to pay the monthly installments, in 1974, Citibank filed a complaint for sum of money and replevin with the Court of First Instance of Manila. Anama filed his answer with counterclaim alleging that his failure to pay was due to the fault of Citibank as it refused to receive the checks he issued, and that the chattel mortgage was defective and void.  The Regional Trial Court (RTC) issued an Order of Replevin over the machineries and equipment covered by the chattel mortgage. 

In 1982, the CA rendered a decision in favor of Anama and nullified RTC’s orders of seizure. However, during the pendency of the case in the CA, the court’s records including the records of the subject case was destroyed by fire. 

In 2009, Anama filed a petition for reconstruction of record and revival of judgment with the CA. Citibank argued that the petition should be dismissed as an action for revival of judgment is within the exclusive original jurisdiction of the RTC. It also argued that laches has set in against Anama for having slept on his rights for almost 10 years. The CA denied the petition for lack of jurisdiction since actions for revival of judgments is with the RTC.

Anama argued that his petition for revival of judgment should be filed in the court that issued the judgment sought to be revived, the CA in this case. 

ISSUE

Whether or not CA did not err in dismissing the petition to revive judgment on the ground of lack of jurisdiction.

RULING

No, jurisdiction over a petition to revive judgment is properly with the RTCs. Thus, the CA is correct in holding that it does not have jurisdiction to hear and decide Anama’s action for revival of judgment.The nature of an action, as well as which court or body has jurisdiction over it, is determined based on the allegations contained in the complaint of the plaintiff, irrespective of whether or not the plaintiff is entitled to recover upon all or some of the claims asserted. Jurisdiction being 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.

DOCTRINE

• In determining the jurisdiction of an action whose subject is incapable of pecuniary estimation, the nature of the principal action or remedy sought must first be ascertained
• Venue and jurisdiction are entirely distinct matters. Jurisdiction may not be conferred by consent or waiver upon a court which otherwise would have no jurisdiction over the subject matter of an action; but the venue of an action as fixed by statute may be changed by the consent of the parties and an objection that the plaintiff brought his suit in the wrong county may be waived by the failure of the defendant to make a timely objection. In either case, the court may render a valid judgment.