G.R. No. L-12173; January 28, 1961
MAMERTO DAILISAN, ET AL., plaintiffs-appellants, vs. SEBASTIAN SO ENG SO, ET AL., defendants-appellees.

FACTS

This case originated from a criminal conviction for homicide through reckless imprudence against Bernardo Libawan. The heirs of the victim, Antonio Dailisan, reserved their right to file a separate civil action for damages. Consequently, appellants Mamerto Dailisan and Felicidad Romero filed a civil case in the Court of First Instance of Davao seeking to recover P67,000.00 in total damages from Libawan and defendants Sebastian So Eng So (the car owner) and Yao Lam. The complaint alleged employer-employee relationship to hold So Eng So subsidiarily liable.
The established facts show that on December 28, 1950, So Eng So ordered his regular driver, Andres Romeo, to drive Yao Lam to Calinan. Romeo, feeling unwell, asked his friend Bernardo Libawan—also a driver but not in So Eng So’s employ—to drive the car without the owner’s knowledge or consent. While Libawan was driving, he struck and killed Antonio Dailisan. The trial court found Libawan guilty of reckless imprudence.

ISSUE

The core issue is whether the case should be decided by the Supreme Court or remanded to the Court of Appeals, considering a change in the law regarding jurisdictional amounts during the pendency of the appeal.

RULING

The Supreme Court remanded the case to the Court of Appeals. The legal logic hinges on jurisdiction determined by the amount in controversy at the time of the appellate court’s decision, not at the filing of the appeal. The case was elevated to the Supreme Court because the claimed damages exceeded P50,000.00, which was then the jurisdictional threshold for the Supreme Court in cases involving only questions of fact.
However, while the case was pending, Republic Act No. 2613 amended the Judiciary Act, increasing the appellate jurisdictional amount to P200,000.00. Since the amount sought in this case is P67,000.00, it fell within the new exclusive appellate jurisdiction of the Court of Appeals. Furthermore, the Supreme Court noted that the principal question presented by the appellants—whether Libawan was an employee of So Eng So at the time of the accident—is a factual issue. Under the amended law, the Court of Appeals has final jurisdiction over factual questions in cases where the amount does not exceed P200,000.00. Therefore, the Supreme Court, applying the law in force at the time of its decision, correctly ordered the remand of the case for proper adjudication by the Court of Appeals.