G.R. No. 1825 : August 17, 1905

FACTS:
Isabelo Artacho filed a complaint in the Court of First Instance against the Provincial Board of Pangasinan. He alleged that the Board had adopted an ordinance authorizing the seizure of animals found in the public park of Lingayen and their release to owners only upon payment of a fine. Artacho contended this ordinance was illegal and beyond the Board’s authority. He further claimed that under this ordinance, provincial authorities had seized his goat, which was never returned. In his prayer for relief, he sought: (1) a judicial declaration that the ordinance was illegal and void; (2) an order for the Board to return the goat or pay its value (₱25); and (3) an order for the Board to pay him damages (₱30). The lower court dismissed the case, holding that the principal object of the action was to recover sums of money (₱25 and ₱30), which fell within the exclusive jurisdiction of a justice of the peace, not the Court of First Instance.

ISSUE:
Whether the Court of First Instance correctly dismissed the case for lack of jurisdiction on the ground that the action was principally for the recovery of sums aggregating less than ₱100, and therefore within the exclusive jurisdiction of a justice of the peace.

RULING:
No. The Supreme Court reversed the judgment of the lower court. It held that the principal object of the action was to obtain a judicial declaration that the provincial ordinance was illegal and void. The claims for the return of the goat (or its value) and for damages were merely ancillary or incidental to this primary objective. An action seeking to invalidate a provincial ordinance is one “in which the subject of litigation is not capable of pecuniary estimation” under paragraph 1, section 56 of Act No. 136 (The Judiciary Act). Such actions fall within the original jurisdiction of the Court of First Instance, as justices of the peace have no jurisdiction to pass upon the validity of provincial ordinances. The case was remanded to the lower court to proceed on the merits. The Supreme Court expressly refrained from ruling on whether an ordinary action (as filed) or a special action like certiorari was the proper remedy, leaving that determination to the Court of First Instance upon remand.