G.R. No. L-18096; January 31, 1963
MARIA ABON, ET AL., plaintiffs-appellants, vs. AMPARO E. PABLO and LILY E. PABLO, defendants-appellees.

FACTS

The plaintiffs-appellants are fifty-one tenants occupying portions of a property owned by defendants-appellees in Sta. Ana, Manila, paying individual monthly rents ranging from P5.00 to P10.00. After December 31, 1953, the appellees required and collected increased rents from the appellants. The appellants filed a complaint in the Court of First Instance of Manila, alleging that this rent increase violated Section 5 of Republic Act 1162, as amended, which prohibits rent increases on landed estates in Manila authorized for expropriation as of that date. They sought to recover the total excess payments of P6,843.68, plus exemplary damages treble each individual claim, attorney’s fees, and costs.
The defendants-appellees moved to dismiss the complaint on the grounds that it failed to state a cause of action, arguing their one-hectare property was not a “landed estate” under the law, and that the rent increase was lawful due to a corresponding increase in land tax assessment. The trial court granted the motion to dismiss, ruling not only on the insufficiency of the cause of action but also that it lacked jurisdiction over the subject matter.

ISSUE

Whether the Court of First Instance had jurisdiction over the subject matter of the action.

RULING

The Supreme Court affirmed the order of dismissal, ruling that the Court of First Instance correctly held it lacked jurisdiction. The legal logic hinges on the application of jurisdictional rules governing joinder of parties and claims. Under Section 6, Rule 3 of the Rules of Court, when multiple plaintiffs join in a single complaint, each asserting a separate and distinct money claim against the same defendant, the jurisdictional amount is determined by the value of each individual claim, not by the aggregate sum of all claims. The Court cited established precedent (Soriano y Cia vs. Jose; Argonza vs. International, etc.) affirming this principle.
In this case, each appellant tenant sought to recover individual excess rent payments, with the largest individual claim undisputedly not exceeding P5,000.00. Therefore, the jurisdictional test was met by the Municipal Court of Manila, not the Court of First Instance, pursuant to the jurisdictional limits set by Section 88 of the Judiciary Act, as amended. Since the jurisdictional issue was dispositive, the Supreme Court deemed it unnecessary to rule on the substantive question of whether the complaint alleged a sufficient cause of action regarding the property’s status as a landed estate under Republic Act 1162. The dismissal was upheld on jurisdictional grounds alone.