G.R. No. L-12800; August 5, 1960
MELECIO CAJILIG, et al., plaintiffs-appellees, vs. FLORA ROBERSON CO., defendant-appellant.

FACTS

On April 25, 1955, thirty-three (33) crew members of the M.S. “Alex” filed a suit in the Court of First Instance of Iloilo against Flora Roberson Co., the administratrix of the estate of the deceased owner Jovito Co. They sought to recover amounts deducted from their salaries for the value of lodging furnished on board the vessel. The aggregate claim was P15,142.40, but no individual claim exceeded P534.00. During the case, five plaintiffs withdrew. The remaining plaintiffs entered into an agreed statement of facts with the defendant regarding the exact amounts of their claims. The trial court ruled that the defendant had no right to make the deductions, as the lodging did not constitute “furnishing or housing” under the Minimum Wage Law, and ordered reimbursement with interest and attorney’s fees. The defendant appealed. Before her record on appeal was approved, she moved to dismiss the case on the ground that since each plaintiff’s individual claim did not exceed P600, the case fell within the exclusive jurisdiction of the inferior court, not the Court of First Instance. The trial court denied the motion, stating the case had already been decided, and transmitted the record on appeal to the Supreme Court.

ISSUE

Whether the Court of First Instance had jurisdiction over the complaint, considering that each plaintiff’s individual claim did not exceed P600, despite the aggregate claim exceeding that amount.

RULING

The Supreme Court ruled that the Court of First Instance did not have jurisdiction. The jurisdiction is determined by the amount of each separate claim, not the aggregate total of all claims, where several plaintiffs have separate and distinct claims against a common defendant arising from the same transaction or series of transactions. This rule, established in prior jurisprudence (A. Soriano y Cia. vs. Jose, International Colleges, Inc. vs. Argonza, etc.), was codified in the amendment to Section 88 of the Judiciary Act by Republic Act No. 2613 . Since each plaintiff’s claim did not exceed P600, the case properly fell within the exclusive jurisdiction of the inferior court. The trial court’s refusal to dismiss the case because it had already rendered a decision was erroneous, as jurisdiction is conferred by law and cannot be conferred by consent or waived; an objection to lack of jurisdiction can be raised at any stage, even on appeal. Consequently, all proceedings in the lower court, including its judgment, were null and void. The Court rejected the appellees’ argument that the case involved a violation of the Minimum Wage Law giving the Court of First Instance jurisdiction to restrain violations, holding that the action was one for recovery of wages/underpayment, which under the Act must be brought in “any competent court” based on the jurisdictional amount. The Supreme Court, having no appellate jurisdiction over a case originally outside the trial court’s jurisdiction, dismissed the complaint. Costs were imposed on the plaintiffs-appellees.