G.R. No. L-16732; May 29, 1962
RAMON AUGUSTO, ET AL., plaintiffs-appellants, vs. ARCADIO ABING, ET AL., defendants-appellees.

FACTS

On June 5, 1958, nine residents of Barrio Mactan, Opon, Cebu, filed a complaint against the members of the Barrio Council. They alleged that the Council, in a resolution, falsely represented that the plaintiffs had agreed to grant a right of way over their lands for a road construction without compensation. Subsequently, without any expropriation proceedings, workers entered their properties, destroyed crops, and began building the road. Each plaintiff specified separate amounts for actual damages, ranging from P120 to P415, totaling P1,956 collectively. They also collectively sought P9,000 in moral damages (P1,000 each) and attorney’s fees.
The defendants moved to dismiss the complaint on the ground that the Court of First Instance of Cebu lacked jurisdiction. They argued that the jurisdictional amount was determined by each plaintiff’s individual claim, all of which were below the then P2,000 threshold for the court’s original jurisdiction. The trial court agreed and dismissed the complaint for want of jurisdiction, prompting the plaintiffs’ appeal.

ISSUE

What amount serves as the basis for determining court jurisdiction when several plaintiffs, with separate claims, jointly sue several defendants: the individual claim of each plaintiff or the aggregate sum of all claims?

RULING

The Supreme Court affirmed the trial court’s order of dismissal, ruling that jurisdiction is determined by the amount of each plaintiff’s separate and distinct claim, not by the aggregate total of all claims. The Court applied the settled doctrine established in Cajilig, et al. vs. Co, which holds that when multiple plaintiffs with separate claims arising from the same transaction or series of transactions jointly sue a common defendant, the test for jurisdiction is the value of each individual claim.
The legal logic is grounded in the nature of the claims. Although the plaintiffs’ causes of action arose from a common event (the road construction and alleged misrepresentation), their rights to damages remained separate and distinct. Each plaintiff suffered damage to their own property and calculated their own specific losses. Permitting aggregation of claims to confer jurisdiction would allow circumvention of jurisdictional rules designed to allocate cases between inferior and superior courts based on the value of the singular matter in controversy per party. Consequently, since each appellant’s claim for actual damages was less than P2,000, the Court of First Instance correctly found it lacked original jurisdiction. The appeal was dismissed.