G.R. No. L-14947; February 28, 1963
MAURICIO MIRANO, ET AL., plaintiffs-appellants, vs. MADRIGAL & COMPANY, INC., defendant-appellee.

FACTS

The plaintiffs, twenty-five seamen, were contracted by Madrigal & Company in November 1941 to crew three vessels to Hong Kong for dry-docking. Upon arrival, war broke out, and they were captured by Japanese forces on December 15, 1941. They were interned and forced into labor until their escape in September 1944. They filed a complaint in the Court of First Instance (CFI) of Manila in 1953 to recover unpaid wages from November 1941 to September 1944, totaling P56,561.24, plus damages. The defendant moved to dismiss, arguing, among other grounds, that the CFI lacked jurisdiction over the claims of nineteen plaintiffs whose individual wage demands were P2,000.00 or less, as such amounts fell under the exclusive original jurisdiction of inferior courts under the Judiciary Act.
The trial court initially denied the motion to dismiss, believing the claims arose from a single written contract (“shipping articles”). However, after trial, it found the evidence showed each seaman had individually signed separate shipping articles with the defendant. Consequently, the court dismissed the complaints of all plaintiffs except Mauricio Mirano, whose claim exceeded P2,000.00, holding that for the others, their individual claims determined jurisdiction and were below the CFI’s jurisdictional amount.

ISSUE

Whether the Court of First Instance had jurisdiction over the claims of the plaintiffs whose individual demands were P2,000.00 or less, considering they filed a single complaint for collective recovery of wages.

RULING

No, the CFI lacked jurisdiction over those individual claims. The Supreme Court affirmed the trial court’s dismissal. The legal logic hinges on the application of the jurisdictional rules under the Judiciary Act regarding joinder of causes of action. The general rule is that when multiple causes of action between the same parties are joined in one complaint, the sum total of all claims determines the court’s jurisdiction. However, a critical exception exists: when the claims joined are “separately owned by or due to” different parties, the jurisdictional test is applied to each separate claim individually. Here, while the plaintiffs joined in one complaint, their causes of action were based on individual employment contracts (the separate shipping articles). Each seaman had a distinct and separate contractual right to his own wages. Therefore, they were considered to have separate and distinct ownership over their respective claims. Applying the exception, the court must look at the amount of each plaintiff’s individual demand to determine jurisdiction. Since the claims of the dismissed plaintiffs were for P2,000.00 or less, they fell under the exclusive original jurisdiction of the municipal or justice of the peace courts, not the CFI. The claim of appellant Mauricio Mirano, exceeding P2,000.00, was correctly retained by the CFI for adjudication on the merits.