GR L 18103; (February, 1964) (Digest)
G.R. No. L-18103; February 29, 1964
OSCAR LAGMAN and ROBERTA ANGELES, plaintiff-appellees, vs. INVESTMENT PLANNING CORPORATION OF THE PHILIPPINES, defendant-appellant.
FACTS
Plaintiff Oscar Lagman won the first prize in a contest conducted by defendant Investment Planning Corporation. The prize consisted of two round-trip tickets to Hong Kong and a seven-day hotel stay. The defendant encountered difficulties securing Central Bank approval for the foreign exchange needed for the tickets. After eventual approval, the defendant provided Lagman with funds totaling P1,380, instructing him to procure the tickets and cover expenses, with promises of reimbursement for any deficit. Lagman used P866 for one ticket, associated taxes, visa and passport fees, and negotiation expenses. This left insufficient funds to purchase the second ticket for his companion, Roberta Angeles, or to cover the agreed P840 for hotel accommodations. Lagman proceeded to Hong Kong alone for ten days. He then sued for the unpaid balance of the prize, claiming the shortfall of P982 needed to cover the second ticket and the hotel stay, plus damages.
The Court of First Instance of Manila ruled in favor of Lagman. The trial court found the expenses incurred by Lagman for the ticket, taxes, and fees to be justified and incidental to the prize. It held the defendant liable for the balance of P982, representing the cost of the second ticket and the hotel accommodation, plus attorney’s fees. The defendant appealed the decision.
ISSUE
The primary legal issue is whether the Supreme Court has jurisdiction over the direct appeal filed by the defendant.
RULING
The Supreme Court did not rule on the merits of the collection case. Instead, it resolved the appeal on jurisdictional grounds. The Court highlighted that the defendant, in its brief, explicitly stated it was appealing “on questions of law and of fact.” An appeal involving both questions of law and fact falls within the appellate jurisdiction of the Court of Appeals, not the Supreme Court. Furthermore, the Court noted that the amount involved in the controversy did not exceed P200,000, which also placed the appeal within the jurisdiction of the Court of Appeals under the governing statutes. Consequently, the Supreme Court held that it lacked jurisdiction to entertain the direct appeal. The case was remanded to the Court of Appeals for proper adjudication. The ruling underscores the mandatory nature of jurisdictional rules regarding the hierarchy of courts and the proper forum for appeals based on the nature of the questions raised and the amount involved.
