G.R. No. L-13118. April 28, 1960.
MACONDRAY & COMPANY, INC., plaintiff-appellant, vs. DELGADO BROTHERS, INC., defendant-appellee.

FACTS

Plaintiff-appellant Macondray & Company, Inc., as agent for the MS PLEASANTVILLE, filed a complaint in the Court of First Instance of Manila against defendant-appellee Delgado Brothers, Inc., the operator of pier services in the Port of Manila. The complaint alleged that on April 17, 1955, the defendant received 68 cartons of paint unloaded from the MS PLEASANTVILLE for transshipment to Iloilo. When the cargo was about to be loaded onto the MV JOLO, the defendant delivered only 59 cartons, failing to deliver 9 cartons. After the MV JOLO departed, the defendant offered 9 replacement cartons, but these were rejected by the consignee and had to be sold at a reduced price, resulting in a loss of P209.98, which the plaintiff paid to the consignee. The plaintiff demanded payment of this sum from the defendant, but the defendant refused. The complaint sought recovery of P209.98 with interest, plus P300.00 as attorney’s fees and litigation expenses. The defendant filed a motion to dismiss on the ground that the court lacked jurisdiction because the amount demanded was less than P2,000. The lower court granted the motion and dismissed the complaint. The plaintiff appealed, arguing that the case falls under admiralty jurisdiction, which is within the exclusive original jurisdiction of courts of first instance regardless of the amount involved.

ISSUE

Whether the Court of First Instance of Manila has jurisdiction over the subject matter of the case, specifically, whether the dispute involves admiralty or maritime jurisdiction such that the court’s jurisdiction is not limited by the amount in controversy.

RULING

No. The Supreme Court affirmed the order of dismissal, holding that the case does not involve admiralty or maritime jurisdiction. The Court explained that admiralty jurisdiction covers only maritime matters and the administration of maritime law. The dispute here concerns the defendant’s duty as a custodian or depositary of the goods (68 cartons of paint) to take care of them and deliver them to the entitled party. This duty is the same as that of any ordinary depositary and would exist even if the goods’ final destination were Manila instead of Iloilo, or if the goods were not imported. The issues raised—whether the defendant fully delivered the goods and the amount of indemnity—do not require the application of maritime law and do not affect navigation or maritime commerce. The foreign origin of the goods is immaterial to the applicable law, the rights of the parties, or the procedure for settling the dispute. The Court cited the principle that when a controversy involves both maritime and non-maritime matters, and the principal matter belongs to the jurisdiction of a common law or equity court, admiralty will not take cognizance of incidental maritime matters but will relegate the whole controversy to the appropriate tribunal. Therefore, the plaintiff’s theory that admiralty jurisdiction applies was rejected, and the lower court’s dismissal for lack of jurisdiction was upheld. Costs were imposed on the plaintiff-appellant.