PEOPLE vs.

VELASCO (252 SCRA 135)

FACTS: Respondent was apprehended in a buy bust operations in Tondo resulting to her conviction. Respondent-appellant raises a
single error in her "Appellant's Brief", namely: that the trial court erred in admitting the decks of shabu in evidence against her
because they were obtained through a warrantless arrest and search.2 It appears from her "Reply Brief with Motion To Dismiss",
however, that appellant likewise assails the jurisdiction of the trial court (RTC) over the case.3
And so she posits that there being no valid warrantless arrest, the search incidental thereto which yielded several decks of "shabu"
is, perforce, illegal.

Issue of jurisdiction: appellant argues that in line with the case of "People v. Simon"4 which provides for the gradation of penalties
depending on the amount of drugs involved, her maximum prison term should only be six (6) years inasmuch as the decks of shabu
seized from her do not even amount to one gram. Her case is, she concludes, cognizable by the appropriate Metropolitan Trial Court,
considering the passage of R.A. 76915 (effective on April 15, 1994) which expanded the jurisdiction of said inferior court to include
exclusive jurisdiction over all offenses punishable with imprisonment not exceeding six years, and in effect divested the Regional
Trial Court of jurisdiction over her case.

ISSUE: WON the RTC has jurisdiction over the case. YES

RATIO: R.A. 7659 introduced die following amendment:

Otherwise, if the quantity involved is less than the foregoing quantities, the penalty shall range from prision correccional to
reclusion perpetua 16 depending upon the quantity.
Evidence uncontroverted by the prosecution shows that the total amount of shabu involved in the instant prosecution is less than
one gram. Thus, as correctly argued by appellant, in the absence of any mitigating and aggravating circumstances, the penalty
properly imposable upon her should be the same as the penalty imposed in the Martinez case where the Court held that the penalty
of reclusion perpetua to death and a fine as a conjunctive penalty shall be imposed only when the shabu involved is 200 grams or
more, otherwise if the quantity involved is less than the foregoing, the penalty shall range from prision correccional to reclusion
temporal minus the fine.

R.A. 7691 - expanded the jurisdiction of MTC/MCTC which vested exclusive original jurisdiction over all offenses punishable with
imprisonment not exceeding six years. R.A. 7691 did not divest the Regional Trial Court of jurisdiction over the cases. General rule -
the jurisdiction of a court to try a criminal action is to be determined by the law in force at the time of the institution of the action.
Where a court has already obtained and is exercising jurisdiction over a controversy, its jurisdiction to proceed to the final
determination of the cause is not affected by new legislation placing jurisdiction over such proceedings in another tribunal. Exception
–when the statute expressly provides, or is construed to the effect that it is intended to operate as to actions pending before its
enactment. Where a statute changing the jurisdiction of a court has no retroactive effect, it cannot be applied to a case that was
pending prior to the enactment of a statute.

At the time the case against the appellant was filed, the Regional Trial Court had jurisdiction over the offense charged, inasmuch as
Section 39 of R.A. 6425 (the Dangerous Drugs Act of 1972 prior to the amendments introduced by R.A. 7659 and R.A. 7691),

In fine, the jurisdiction of the trial court (RTC) over the case of the appellant was conferred by the aforecited law then in force (R.A.
6425 before amendment) when the information was filed. Jurisdiction attached upon the commencement of the action and could not
be ousted by the passage of R.A. 7691 reapportioning the jurisdiction of inferior courts, the application of which to criminal cases is,
to stress, prospective in nature.

ACCORDINGLY, under all the foregoing premises, the judgment of conviction rendered by the court a quo against the accused-
appellant Yolanda Velasco y Pamintuan is AFFIRMED, but with the MODIFICATION that the proper imposable sentence should be the
indeterminate penalty of six (6) months of arresto mayor as the minimum, to four (4) years and two (2) months of prision
correccional as the maximum thereof However, it appearing from the records that the appellant has been in jail for more than 4
years and 2 months,26 thereby having served more than the maximum imposable penalty, her immediate release from custody is
hereby ordered, unless she is otherwise detained for some other cause.

JOSE ARUEGO, et al vs. CA and ANTONIA ARUEGO (GR 112193)

FACTS: A complaint was filed for Compulsory Recognition and Enforcement of Successional Rights to the RTC by private respondent
Antonia F. Aruego and her alleged sister Evelyn F. Aruego. The complaint avers that the late Jose M. Aruego, Sr., a married man,
had an amorous relationship with Luz M. Fabian. Out of this relationship were born Antonia F. Aruego and Evelyn F. Aruego. The
complaint prayed for an Order praying that herein private respondent and Evelyn be declared the illegitimate children of the
deceased Jose M. Aruego, Sr.; that herein petitioners be compelled to recognize and acknowledge them as the compulsory heirs of
the deceased Jose M. Aruego; that their share and participation in the estate of their deceased father be determined and ordered
delivered to them. The main basis of the action for compulsory recognition is their alleged "open and continuous possession of the
status of illegitimate children". Petitioners denied all these allegations. The lower court rendered its decision ordering the recognition
of Antonia Aruego and the delivery the latter’s share of estate.

Herein petitioners filed a Motion for Partial Reconsideration of the decision alleging loss of jurisdiction on the part of the trial court
over the complaint by virtue of the passage of the Family Code of the Philippines. This motion was denied by the lower court. A
Petition for Prohibition and Certiorari with prayer for a Writ of Preliminary Injunction was filed by herein petitioners before
respondent Court of Appeals, the petition was dismissed for lack of merit. Hence, this petition.

Petitioners contend that with the New Family Code the trial court lost jurisdiction over the complaint of private respondent on the
ground of prescription, considering that under the New Family Code, it is provided that an action for compulsory recognition of
illegitimate filiation, if based on the "open and continuous possession of the status of an illegitimate child," must be brought during
the lifetime of the alleged parent without any exception, otherwise the action will be barred by prescription. Petitioners, further,
maintain that even if the action was filed prior to the effectivity of the Family Code, this new law must be applied to the instant case
as provided that the Code dhall have retroactive effect insofar as it does not prejudice or impair vested of acquired rights in
accordance with the Civil Code or other laws.

ISSUE: Should the provisions of the Family Code be applied in the instant case? NO. WON the RTC lost its jurisdiction on the case in
view of the enactment of the New Family Code

RATIO: The present law cannot be given retroactive effect insofar as the instant case is concerned, as its application will prejudice
the vested right of private respondent to have her case decided under Article 285 of the Civil Code. The right was vested to her by
the fact that she filed her action under the regime of the Civil Code. Prescinding from this, the conclusion then ought to be that the
action was not yet barred, notwithstanding the fact that it was brought when the putative father was already deceased, since private
respondent was then still a minor when it was filed, an exception to the general rule provided under Article 285 of the Civil Code.

Hence, the trial court, which acquired jurisdiction over the case by the filing of the complaint, never lost jurisdiction over the same
despite the passage of the Family Code. The ruling herein reinforces the principle that the jurisdiction of a court, whether in criminal
or civil cases, once attached cannot be ousted by subsequent happenings or events, although of a character which would have
prevented jurisdiction from attaching in the first instance, and it retains jurisdiction until it finally disposes of the case. 8

The fact of filing of the petition already vested in the petitioner her right to file it and to have the same proceed to final adjudication
in accordance with the law in force at the time, and such right can no longer be prejudiced or impaired by the enactment of a new
law. The trial court is, therefore, correct in applying the provisions of Article 285 of the Civil Code and in holding that private
respondent's cause of action has not yet prescribed.

The petition is DENIED and the decision of the Court of Appeals AFFIRMED.

ATLAS FERTILIZER CORPORATION vs. NAVARRO (149 SCRA 432)

FACTS: Private respondent Emiliano C. Beneza was employed by petitioner Atlas Fertilizer Corporation as a salesman and later as a
sales supervisor for eastern Visayas and northern Mindanao. The petitioner advised the private respondent of his impending
termination on the grounds of inefficiency and loss of trust and confidence. In the same memorandum, he was given the option to
resign and possibly receive a little gratuity or wait for the termination order and risk criminal charges. Respondent filed his
resignation letter. The respondent filed with the RTC Cebu, a complaint against the petitioner for injunction with damages with a
prayer for a writ of preliminary injunction and/or restraining order. The complaint urged the court to prevent the respondent's
termination on the grounds that the causes alleged by the petitioner were false and fabricated and that any termination would be
unlawful because he had already tendered his resignation.

The petitioner accepted respondent's resignation and informed the respondent that his claim for termination pay was denied, being
incompatible with his resignation. After the effectivity of respondent's resignation, employer-employee relationship between the
parties was legally severed and that the respondent was not entitled to separation pay benefits. The respondent's motion for
reconsideration was denied which was affirmed by the National Labor Relations Commission.

The petitioner filed with the Regional Trial Court a motion to dismiss the complaint on the ground that the court lacked jurisdiction
over the subject matter of the complaint when Presidential Decree No. 1691 (which transferred to the National Labor Relations
Commission the jurisdiction over "all money claims of workers) was enacted. An opposition was filed by the respondent on the
grounds that the instant case had been consolidated with another case, entitled "Atlas Fertilizer Corporation v. Emiliano C. Belleza"
and a joint trial thereof had been started and that at the time Presidential Decree No. 1691 was approved, this case had already
been filed with the respondent court which maintains its jurisdiction the full termination of the case. The lower court denied the
petitioner's motion to dismiss. Hence, this petition for certiorari and prohibition with prelim injunction.

ISSUE: WON regular courts have jurisdiction to entertain labor cases including those involving claims for moral and other damages
which are pending upon the enactment of PD 1691. SC uphold the petitioner's view

RATIO: It is a general rule that the jurisdiction of a court is determined by the statute enforced at the time of the commencement of
the action. In conflicts of jurisdiction between the courts and the labor agencies arising from the amendments effected by P.D. 1691
on P.D. 1367, this Court held in other cases that PD 1691 is a curative statute which corrected the lack of jurisdiction of the Labor
Arbiter at the start of the proceedings and, therefore, should be given a retrospective application to the pending proceedings. P.D.
1691 merely restored a jurisdiction earlier vested in Labor Arbiters before the enactment of P.D. 1367. It was intended to correct a
situation where two tribunals would have jurisdiction over separate issues arising from the same labor conflict.

The issuance of Presidential Decree No. 1691 and the enactment of Batas Pambansa Blg. 130, made clear that the exclusive and
original jurisdiction for damages would once again be vested in labor arbiters, and on policy grounds, and in the interest of greater
promptness in the disposition of labor matters, a court is spared the often onerous task of determining what essentially is a factual
matter, namely, the damages that may be incurred by either labor or management as a result of disputes or controversies arising
from employer-employee relations.

P.D. 1691 should, therefore, be given a retroactive application to this pending case as the precise purpose of the amendment was to
hopefully settle once and for all the conflict of jurisdiction between regular courts and labor agencies.

The petition is GRANTED and the orders of the respondent court are hereby SET ASIDE. The respondent judge is directed to dismiss
Civil Case No. 17740 without prejudice to the right of the respondent to refile his case with the proper labor agency.