G.R. No. L-15882. November 30, 1962.
EULOGIA MINAY, ET AL., plaintiffs-appellants, vs. BARTOLOME BUENAVENTURA and MARIA JANDUSAY, defendants-appellants.

FACTS

On November 30, 1950, Elena Buenaventura Vda. de Minay and her children (the Minays) executed a Deed of Absolute Sale over a house and lot in Boac, Marinduque, in favor of Bartolome Buenaventura, Elena’s brother. The deed stated the total price was P4,500, with a P1,250 down payment received at various times and a balance of P3,250. The instrument contained a critical stipulation: the purchaser had no right to dispose of the property until fully paid, and if the balance was not paid within five years, the deed would become void, the property would revert to the sellers, and payments made would be forfeited.
After the five-year period lapsed without the defendants-appellants, Bartolome Buenaventura and Maria Jandusay, paying the balance, the Minays filed an action in the Court of First Instance of Oriental Mindoro for rescission of the deed and recovery of the property. The trial court ruled in favor of the Minays, declaring the deed null and void, ordering the defendants to deliver the property and to pay attorney’s fees, and dismissing the defendants’ counterclaim.

ISSUE

Whether the Supreme Court has appellate jurisdiction to review the trial court’s decision, considering the nature of the errors assigned and the value of the property in litigation.

RULING

The Supreme Court ruled that it did not have appellate jurisdiction and ordered the remand of the case to the Court of Appeals. The legal logic is grounded on jurisdictional rules. The defendants’ appeal raised assignments of error that were predominantly questions of fact, such as whether the deed was void, whether the purchase price was fully paid, and the propriety of the award for attorney’s fees. The Supreme Court’s jurisdiction over direct appeals is generally limited to questions of law.
Furthermore, the Court explicitly noted the monetary jurisdictional limit. The value of the property in dispute was P4,500, which was “far below the jurisdictional amount” required for the Supreme Court to exercise its appellate jurisdiction at the time under the Judiciary Act of 1948. The trial judge had also previously directed in an order that the record on appeal be forwarded to the Court of Appeals. Consequently, applying Sections 17 and 29 of the Judiciary Act, the Supreme Court held that the Court of Appeals was the proper forum to review the factual determinations of the trial court. The records were thus remanded for proper disposition.