G.R. No. L-15498. July 31, 1962.
LUCAS ROQUE, ET AL., plaintiffs; LUCAS ROQUE, plaintiff-appellant, vs. SAN MIGUEL BREWERY, INC., defendant-appellee, PHILIPPINE STEAM NAVIGATION COMPANY, defendant-appellant.

FACTS

The plaintiffs, led by Lucas Roque, filed a complaint in the Court of First Instance of Manila on November 27, 1956, seeking to recover damages totaling P91,300. They sued San Miguel Brewery, Inc., Philippine Steam Navigation Company, and its agent, Philippine Everett Steamship Corporation. The claim arose from injuries sustained by Lucas Roque, a passenger aboard the M/S Kolumbugan, on October 17, 1956. The injuries were allegedly caused by the explosion of an oxygen tank owned by San Miguel Brewery due to the defendants’ negligence. The complaint also cited the vessel’s failure to sail without justifiable cause and other acts of omission.
After trial, the lower court rendered its decision on February 26, 1959. It sentenced only the Philippine Steam Navigation Company to pay Lucas Roque the sum of P11,294 for hospitalization, doctor’s fees, additional recuperation expenses, lost income, and attorney’s fees. The case was dismissed against Everett Steamship Corporation. The court also dismissed the cross-claim by Philippine Steam Navigation against San Miguel Brewery and the latter’s counterclaim. Both Lucas Roque and the Philippine Steam Navigation Company gave notices of appeal to the Supreme Court.

ISSUE

The primary procedural issue is whether the Supreme Court or the Court of Appeals has appellate jurisdiction over the appeals interposed by Lucas Roque and the Philippine Steam Navigation Company.

RULING

The Supreme Court, in a Resolution penned by Justice Concepcion, ruled that it did not have jurisdiction and ordered the record of the appeal certified to the Court of Appeals. The legal logic is grounded on the statutory distribution of appellate jurisdiction based on the nature of the questions raised and the amount involved. While both appellants invoked the Supreme Court’s jurisdiction, the Philippine Steam Navigation Company did not file any brief. The brief filed by appellant Lucas Roque raised mainly questions of fact.
Under Sections 17 and 29 of Republic Act No. 296 (The Judiciary Act of 1948), as amended by Republic Act No. 2613, the Court of Appeals has exclusive appellate jurisdiction over cases where only questions of fact are involved or where the amount in controversy does not exceed P200,000, exclusive of interest and costs. The original claim was for P91,300, and the awarded damages were P11,294. Both amounts fall below the jurisdictional threshold for the Supreme Court’s exclusive jurisdiction over appeals involving purely factual issues. Since the appeal primarily contested factual findings, the case properly pertained to the Court of Appeals. Consequently, pursuant to Section 31 of the same Act, the Supreme Court transferred the case.