G.R. No. L-21293 December 29, 1967
Regino G. Aquizap, plaintiff-appellant, vs. Eugenio Basilio, et al., defendants-appellees.

FACTS

In 1943, Regino G. Aquizap filed a detainer case (Civil Case No. 1) against Eugenio Basilio and Santiago Amos in the justice of the peace court of San Marcelino, Zambales. Judgment was rendered in Aquizap’s favor on September 25, 1943, ordering Basilio to vacate the land and pay damages. Basilio remained in possession, planting and harvesting palay in 1944, 1945, and 1946. In November 1946, possession was delivered to Aquizap via a writ of execution. On December 10, 1946, Aquizap filed a complaint (CC 1150) with the Court of First Instance (CFI) of Zambales to recover the value of the harvested palay and other damages. This complaint was dismissed on July 29, 1953, for Aquizap’s failure to appear at the hearing, “without prejudice to the filing of a new complaint.” On November 3, 1953, Aquizap filed the present action (CC 1631) with the same CFI, seeking payment for 48 cavanes of palay (valued at P528) and P200 in other damages. Basilio died during the proceedings and was substituted by his heirs. The heirs moved to dismiss the amended complaint, arguing it stated no cause of action against them and was barred by the statute of limitations. The lower court dismissed the complaint on the ground of prescription. Aquizap appealed to the Court of Appeals, which certified the appeal to the Supreme Court as only questions of law were involved.

ISSUE

Whether the Court of First Instance of Zambales had jurisdiction over the present action (CC 1631) filed by Aquizap in 1953.

RULING

No. The Supreme Court dismissed the appeal, holding that the CFI had lost jurisdiction over the case. Jurisdiction is determined by the statute in force at the time of the filing of the action. When Aquizap filed his original action in 1946, the CFI had jurisdiction because the demand (P528) exceeded the jurisdictional amount for inferior courts under the then-governing Act No. 136. However, the present action was filed on November 3, 1953, after the Judiciary Act of 1948 took effect on June 17, 1948. This Act gave inferior courts exclusive original jurisdiction over cases where the demand does not exceed P2,000, exclusive of interest and costs. Since Aquizap’s total demand was P728, it fell below the CFI’s jurisdictional minimum. The order dismissing the 1946 action “without prejudice” was final and terminated the CFI’s jurisdiction; the 1953 filing was a completely new action subject to the new jurisdictional law. Consequently, the CFI had no jurisdiction, and the Supreme Court, in turn, lacked appellate jurisdiction to review the case on its merits. The proceedings in the lower court were set aside.