8
II.
REFUTATIONS TO RESPONDENTS’
RESPECTIVE RESPONSES TO THE PETITION
(Responses received by the Petitioners)
2.1. Notably, the crux of respondents’ opposition, as reflected
above, concerns procedural matters, specifically the issue on personal and
subject matter “jurisdiction.” Hence, the petitioners find it prudent to tackle
them first.
2.2. To save paper and avoid unnecessary repetition of counterarguments and discussion, the petitioners presently respond to respondents’
issues and arguments collectively, topically, and sequentially.
A.
The strict interpretation of the concept of
jurisdiction, which requires acquisition of
personal and subject matter jurisdiction
before hearing and deciding a case, is not
applicable to the Honorable Commission,
which has a special mandate under the
Constitution.
2.3. As early as the case of Herrera v. Baretto and Joaquin,13 the
Supreme Court defined jurisdiction as the power to hear and decide cases.14
Jurisdiction is the power with which courts are invested with the power of
administering justice, that is, for hearing and deciding cases. For a court to
have authority to dispose of a case on the merits, it must acquire jurisdiction
over the subject matter and the parties.15
2.4. The noticeable error in respondents’ position is their strict
interpretation and blanket application of the concept of jurisdiction, such that
the Honorable Commission was placed in the same footing as that of a court
of law, which needs to acquire jurisdiction over the subject matter and
parties before it can hear and decide a case.
2.5. The Honorable Commission is not a court of law. Thus, the
term jurisdiction, as defined above, should not be construed and applied in
the current inquiry. The framers of the Constitution intended this
interpretation to hold, as could be gleaned from their deliberations—
“MR. DE LOS REYES: And may I offer an
amendment of [sic] Commissioner Nolledo that instead of
13
25 Phil. 245 (1913)
Herrera v. Baretto and Joaquin, supra., note 13.
15
Republic Planters Bank v. Molina, 166 SCRA 39 [1988].
14