G.R. No. L-14517. February 27, 1961.
SANDRA K. SHAOUY, plaintiff-appellant, vs. PHILIP E. SHAOUY, defendant-appellant.

FACTS

Plaintiff Sandra K. Shaouy filed a complaint against her husband, defendant Philip E. Shaouy, seeking moral damages of P120,000, exemplary damages of P30,000, attorney’s fees, and costs. Her claims were based on allegations related to the defendant’s act of obtaining a divorce decree from a court in Nevada. In his answer, the defendant denied the material allegations and interposed a counterclaim for P50,000 as actual, moral, and punitive damages, plus attorney’s fees.
The Court of First Instance of Manila rendered a decision dismissing both the main complaint and the counterclaim. Dissatisfied, both parties appealed the decision. The case was initially elevated to the Court of Appeals, which then certified it to the Supreme Court because the amount claimed by each party exceeded P50,000, which was then the jurisdictional ceiling for the Court of Appeals.

ISSUE

Whether the Supreme Court has appellate jurisdiction over the case, or if jurisdiction properly lies with the Court of Appeals, considering the amounts claimed and the nature of the issues raised.

RULING

The Supreme Court ruled that it did not have jurisdiction and ordered the remand of the case to the Court of Appeals. The legal logic is grounded on the statutory rules governing appellate jurisdiction based on the value of the controversy. At the time the appeals were perfected, Republic Act No. 296 , as amended, provided that the Court of Appeals had exclusive appellate jurisdiction over cases where the value in controversy did not exceed P200,000. A subsequent amendment, Republic Act No. 2613 , had extended this jurisdictional limit to P200,000.
Examining the claims, the plaintiff’s total demand for damages and fees was P160,000, while the defendant’s counterclaim was P60,000. Neither claim exceeded the P200,000 threshold. Furthermore, the issues raised by both parties in their briefs were predominantly questions of fact, such as whether the act of obtaining a foreign divorce was malicious to justify damages. The resolution of such factual issues falls within the primary competence of the Court of Appeals. Since the aggregate sum claimed by each party was within the appellate jurisdictional limit of the Court of Appeals and the core issues were factual, the Supreme Court held that the case fell within the exclusive appellate jurisdiction of the Court of Appeals. Consequently, the records were remanded for proper determination.