G.R. No. L-13317; April 25, 1960
R. S. PAÑGILINAN & CO., INC., petitioner, vs. HON. JUDGE L. PASICOLAN, ETC., ET AL., respondents.

FACTS

Petitioner R. S. Pañgilinan & Co., Inc., was sued by thirty-two (32) plaintiffs (the respondents, excluding Judge Pasicolan) in Civil Case No. 1088 of the Court of First Instance of Pampanga. The plaintiffs alleged they rendered labor as workers in the construction of Floodgate No. 1 from November 14, 1955, to March 10, 1956. The amended complaint itemized each plaintiff’s number of workdays, daily rate, total wages due, amount paid, and the resulting balance due. The individual balances claimed ranged from P24.00 to P300.00, with the aggregate total of all claims being P4,554.00. The plaintiffs prayed for judgment for this sum, plus attorney’s fees and damages. During trial, respondent Judge Pasicolan initially doubted the court’s jurisdiction because each individual claim was below P2,000.00 (the then minimum jurisdictional amount for Courts of First Instance in civil cases). After requiring memoranda, the Judge, relying on Campos Rueda Corporation vs. Sta. Cruz Timber Company, Inc., concluded the court had jurisdiction and ordered the reception of evidence. Petitioner’s motion for reconsideration was denied, prompting this original action for certiorari to declare the lower court without jurisdiction and to order the dismissal of the case.

ISSUE

Whether the Court of First Instance had jurisdiction over Civil Case No. 1088, where thirty-two plaintiffs with separate and distinct claims for unpaid wages, none exceeding P330.00 individually, joined in a single complaint.

RULING

No. The Court of First Instance had no jurisdiction. The Supreme Court granted the writ of certiorari and made the preliminary injunction permanent.
The Supreme Court held that where multiple plaintiffs, each having a separate and distinct demand, join in a single suit, the jurisdictional amount is determined by each individual claim, not by the aggregate sum of all claims. The claims in this case were not joint or indivisible; each plaintiff claimed a specific balance due solely to himself, as detailed in the complaint’s itemized list. Each plaintiff could have sued separately without splitting a cause of action, and a decision on one claim would not bar the others.
The Court distinguished the case from Campos Rueda Corp., which involved one plaintiff against multiple defendants, and noted that the rule therein was subject to exceptions, one being “where the claims joined under the same complaint are separately owned by or due to different parties.” In such a case, “each separate claim furnishes the jurisdictional test.” This principle, previously established in A. Soriano y Cia vs. Jose and International College vs. Argonza, was later incorporated into the Judiciary Act. Since the highest individual claim (P300.00 plus a share of damages and fees, totaling less than P330.00) was within the exclusive original jurisdiction of justice of the peace and municipal courts (which handled claims under P2,000.00), the Court of First Instance had no jurisdiction. The case was ordered dismissed.