GR L 36098; (January, 1983) (Digest)
G.R. No. L-36098. January 21, 1983. ORTIGAS & COMPANY, LIMITED PARTNERSHIP, petitioner, vs. JUDGE JOSE B. HERRERA, respondent.
FACTS
On August 14, 1969, Ortigas & Company entered into an agreement to sell a parcel of land to Emiliano Samson for P55,430.00. A special condition stipulated that if Samson completed the construction and painting of his residential house on the lot within two years, Ortigas agreed to refund him P10.00 per square meter. Samson fulfilled the condition and, on May 17, 1971, notified Ortigas in writing and requested the refund of P4,820.00. Upon Ortigas’s failure to pay, Samson filed a complaint for sum of money and damages with the City Court of Manila.
Ortigas filed a motion to dismiss the complaint on grounds including lack of jurisdiction, arguing the action was for specific performance and thus beyond the city court’s pecuniary jurisdiction. Judge Jose B. Herrera held the motion in abeyance until trial. Ortigas then filed a special civil action for certiorari and prohibition with the Court of First Instance (CFI), which dismissed the petition, ruling that the claim, being below P10,000.00, was within the city court’s exclusive jurisdiction. Ortigas elevated the case to the Supreme Court.
ISSUE
Whether the City Court of Manila has jurisdiction over the complaint filed by Emiliano Samson.
RULING
The Supreme Court ruled that the City Court lacked jurisdiction. The action was one for specific performance, not merely for a sum of money, and was therefore incapable of pecuniary estimation, placing it within the exclusive original jurisdiction of the Court of First Instance.
The legal logic hinges on the distinction between actions capable and incapable of pecuniary estimation. An action for the recovery of a sum of money, such as a simple debt, is considered capable of pecuniary estimation. However, where the payment of money is contingent upon the performance or determination of specific conditions, the action is deemed one for specific performance. The core issue becomes the enforcement of contractual obligations and the determination of whether conditions precedent were met, which transcends mere monetary valuation. Here, Samson’s right to the refund arose only upon proof of his completion of the house construction within the stipulated period. Thus, the primary relief sought was the enforcement of Ortigas’s contractual duty to refund based on Samson’s prior performance, making the monetary claim merely incidental. The Supreme Court reversed the CFI’s order and directed the dismissal of the city court case for lack of jurisdiction.