G.R. No. L-13105; August 25, 1960
LUCINA BAITO, plaintiff-appellant, vs. ANATALIO SARMIENTO, defendant-appellee.

FACTS

Plaintiff-appellant Lucina Baito filed a complaint for support against her husband, defendant-appellee Anatalio Sarmiento. The Court of First Instance of Samar dismissed the complaint on the ground of lack of jurisdiction, as the amount demanded as support was only P720. The plaintiff’s motion for reconsideration was denied, prompting this appeal. The core dispute is whether jurisdiction lies with the Court of First Instance or with a justice of the peace/municipal court, given the amount claimed.

ISSUE

Which court has jurisdiction over an action for support when the amount claimed or demanded is only P720 (or not more than P2,000, now P5,000)?

RULING

The Supreme Court ruled that an action for support is not capable of pecuniary estimation. It involves not merely the determination of the amount to be given but also the examination of the parties’ relation, the right to support arising from that relation, the claimant’s needs, and the financial resources of the person from whom support is sought—all matters beyond pecuniary valuation. Therefore, under Section 44(a) of Republic Act No. 296 (as amended by Republic Act No. 2613), such actions fall within the exclusive original jurisdiction of Courts of First Instance, regardless of the amount claimed. The appealed order was set aside, and the case was remanded to the Court of First Instance for further proceedings.
Concurring Opinion (Justice J.B.L. Reyes, joined by Justice Concepcion):
Justice Reyes concurred, adding that the complaint sought recovery of both future and past support overdue, making the amount involved incapable of pecuniary estimation at the time of filing, as it depended on factors such as the parties’ lifetime and other circumstances not apparent from the complaint.