FACTS: On July 4, 2005, PLDT received a letter dated June 23, 2005 from respondent Jimenez, requesting petitioner to pay respondent City business and franchise taxes, invoking Article 243 of the Implementing Rules and Regulations of the Local Government Code and the Revenue Code of the City of Balanga. On July 27, 2005, PLDT replied thereto, copy of which was received by respondents on July 29, 2005. Thereafter, there were exchanges of correspondence between PLDT and respondent Jimenez. On January 20, 2006, PLDT, through counsel, wrote respondents a letter, requesting the latter to cancel and withdraw the assessed tax liabilities imposed upon PLDT. On January 27, 2006, respondent Jimenez denied PLDT’s protest and reiterated that it is subject to both business and franchise taxes. On February 3, 2006, PLDT received the denial of its protest. On March 3, 2006, PLDT appealed the said denial to the Regional Trial Court, Branch 57, Makati City (“RTC”). On May 18, 2006, respondents filed a “Motion To Dismiss” with the RTC ofMakati City. 


HELD: NO. Pursuant to the aforequoted decision of the Supreme Court, the review taken by the RTC over the denial of the protest by the local treasurer would fall within the RTC’s original jurisdiction. In short, the review is the initial judicial cognizance of the matter, as the denial of the protest is not the judgment or order of a lower court, but of a local government official. Having determined the nature of the jurisdiction of the R TC over a denial of a protest by a local treasurer under Section 19 5 of the LGC, We now come to the pivotal issue of which RTC has competent jurisdiction over the appeal taken by petitioner PLDT from the denial of its tax protest by the local City Treasurer ofBalanga City. Petitioner PLDT contends that the RTC of Makati City is the court of competent jurisdiction. We do not agree. 

The territory defined in the law shall be deemed to be the territorial area of the branch concerned for the purpose of determining ( 1) the venue of all suits, proceedings or actions, whether civil or criminal, as well as (2) determining the Metropolitan Trial Courts, Municipal Trial Courts and Municipal Circuit Trial Courts over which the said branch may exercise appellate jurisdiction. The intendment of the law in this regard is  to make, at all times, “the courts accessible to the people of the different parts of the region and making attendance of litigants and witnesses as inexpensive as possible” and to make more speedy the dispatch of judicial business. 

In short, the Regional Trial Courts shall exercise their respective jurisdiction within their territorial limits and territorial limits pertain to the venue over which a judicial power is exercised Pursuant to the foregoing, where the acts of the public official are the object of the litigation, meaning, petitioner seeks to control them, then the suit must be filed in the RTC whose territorial jurisdiction encompasses the place where the respondent public official is found or holding office. For the rule is, outside its territorial limits, the court has no power to enforce its order. In the instant case, PLDT was not only seeking for a review of the denial by the City Treasurer of Balanga City of the tax protest of PLDT, but petitioner was also asking the court to order respondents to perform specific acts, such as, to order respondents to cancel the assessment, to amend the official receipts issued to petitioner, and to enjoin respondents from imposing franchise and business taxes against PLDT; in other words, petitioner PLDT seeks to control the acts of the City Treasurer of Balanga City. 

Hence, the suit ought to be filed in the RTC of Balanga City which has territorial jurisdiction over the City Treasurer of Balanga City. For it is the RTC of Balanga City that has power to enforce its orders over the City Treasurer of Balanga City. Thus, the RTC of Balanga City, and not the RTC of Makati, therefore, is the court of competent jurisdiction over the appeal from the denial by the local City Treasurer of Balanga City of the tax protest of PLDT.

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