G.R. No. L-4768; February 27, 1952
COMPOSTELA LUMBER CO. INC., petitioner, vs. FILOMENA DATU, ENRIQUEZ A. FERNANDEZ, and CIRILO MACEREN, in their capacities as Judges of the Court of First Instance of Davao, and R.A. UNSON, in his capacity as Sheriff of Davao, respondents.

FACTS

In March 1950, respondent Filomena Datu filed a complaint in the Court of First Instance of Davao (Civil Case No. 464) to recover two thousand pesos (P2,000) as damages for the death of her daughter, allegedly caused by a truck driver of petitioner Compostela Lumber Co. Inc. The complaint was never served on the petitioner or its authorized agent. In November 1950, the petitioner was declared in default. In January 1951, respondent Judge Cirilo Maceren rendered a decision ordering the petitioner to pay P2,000 with legal interest and costs. On February 17, 1951, the petitioner first learned of the action and judgment against it. Immediately, the petitioner filed a petition contesting the court’s jurisdiction over the subject matter and its person, and alternatively sought relief under Rule 38. Another respondent judge denied this petition.

ISSUE

Whether the Court of First Instance of Davao had jurisdiction over the subject matter of the complaint, which sought damages of P2,000.

RULING

The Supreme Court granted the petition for certiorari and made the preliminary injunction permanent. The Court held that the complaint explicitly sought judgment for P2,000 and costs. Under Sections 86 to 88 of Republic Act No. 296 (the Judiciary Act of 1948), which was effective at the time, the exclusive original jurisdiction over such a claim fell within the authority of the corresponding justice of the peace court, not the Court of First Instance. Consequently, all proceedings in the Court of First Instance of Davao, including the default judgment, were void from the beginning for lack of jurisdiction over the subject matter. Costs were imposed on respondent Filomena Datu.