G.R. No. L-17430; November 30, 1962
DOMINGO IMPERIAL, ET AL., plaintiffs-appellees, vs. MANILA TIMES PUBLISHING CO., INC., ET AL., defendant-appellants.

FACTS

Plaintiffs Domingo Imperial and Sixto Brillantes were Chairman and a Member, respectively, of the Commission on Elections. On June 2, 1957, defendant Jose L. Guevara, a reporter for the Manila Times Publishing Company, authored a news article headlined “BALLOT BOX CONTRACTS HIT, Solons firms assail poll commission’s irregular action.” The article reported that political quarters were “rocked” by reports of “venalities” in the awarding of a contract to manufacture 34,000 ballot boxes and concluded that Chairman Imperial and Commissioner Brillantes had approved all proceedings, with one member dissenting. This was followed by an editorial and a column on June 5, 1957, questioning the commission’s use of a negotiated sale instead of public bidding.
Deeming the publications libelous, the plaintiffs filed a civil action for damages in the Court of First Instance of Rizal. After trial, the lower court rendered judgment ordering the defendants to pay, jointly and severally, P10,000 as moral damages and P5,000 as exemplary damages to each plaintiff. The defendants appealed directly to the Supreme Court, assigning as errors the trial court’s findings that the publications were libelous and that the defendants were negligent and civilly liable.

ISSUE

Whether the Supreme Court has appellate jurisdiction over the direct appeal filed by the defendants.

RULING

The Supreme Court dismissed the appeal for lack of appellate jurisdiction and ordered its remand to the Court of Appeals. The Court’s ruling was based purely on jurisdictional grounds, without delving into the merits of the libel claims or defenses. The Court emphasized that the amount involved in the appealed judgment was only P15,000 for each plaintiff. This sum fell far below the jurisdictional threshold required for a direct appeal to the Supreme Court under the prevailing law.
Furthermore, the legal issues raised by the appellants—specifically, the character of the articles as libelous, the presence of negligence, and the propriety of the awarded damages—were categorized as questions of fact or mixed questions of law and fact. Under Sections 17(5), 17(6), and 29 of the Judiciary Act of 1948, as amended, such matters fall within the appellate jurisdiction of the Court of Appeals, not the Supreme Court. Consequently, the appeal was erroneously filed with the Supreme Court, which lacked the authority to review the case on its merits. The case was ordered transmitted to the Court of Appeals for proper disposition.