G.R. No. 45028 ; November 25, 1938
Maximo Abary and Victoria Zalameda, plaintiffs-appellants, vs. Fidelino Agawin, defendant-appellee.

FACTS

Plaintiffs-spouses Maximo Abary and Victoria Zalameda filed a complaint against defendant Fidelino Agawin in the justice of the peace court. The complaint alleged two separate loans: a P500 loan obtained by the defendant from both plaintiffs on October 17, 1934, and a P100 loan obtained from plaintiff Victoria Zalameda alone on October 23, 1934. The defendant demurred, arguing that the justice of the peace court lacked jurisdiction because the total claim (P600) exceeded its jurisdictional limit (then P200 to less than P600), and that the complaint failed to state a cause of action. The Court of First Instance sustained the demurrer on the jurisdictional ground and dismissed the case after the plaintiffs did not amend their complaint. The plaintiffs appealed.

ISSUE

Whether the justice of the peace court (and consequently the Court of First Instance on appeal) had jurisdiction over the complaint, considering the two separate loans amounting to a total of P600.

RULING

The Supreme Court reversed the order of dismissal and remanded the case for trial. The Court held that the two loans constituted two independent causes of action, as they were obtained from different obligees (the spouses jointly and the wife alone) on different dates. Jurisdiction of the justice of the peace court is determined by the amount of each separate cause of action, not by the aggregate sum of all causes joined in the complaint. Since each loan (P500 and P100) was within the jurisdictional limit (less than P600), the justice of the peace court had jurisdiction. The Court cited authority that a party cannot combine separate causes of action to deprive a justice’s court of jurisdiction, and the amount of each separate demand controls. The lower court erred in adding the amounts to conclude it lacked jurisdiction.

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