GR L 2030; (January, 1906) (Digest)
FACTS:
Alfred David Oehlers, an alien, filed an action in the Court of First Instance of Manila against Robert Hartwig to recover the statutory penalty of $1,000 under Section 5 of the U.S. Act of Congress of March 3, 1903. Oehlers alleged that Hartwig induced him to migrate to the Philippine Islands to perform labor in violation of said Act. The trial court ruled in favor of Oehlers. Hartwig appealed, contesting the jurisdiction of the Court of First Instance over the suit.
ISSUE:
Whether a Court of First Instance in the Philippine Islands has jurisdiction over an action brought by a private individual to recover the penalty prescribed by Section 5 of the Act of Congress of March 3, 1903.
RULING:
Yes, the Court of First Instance has jurisdiction. The Court held that:
1. Under Section 56 of Act No. 136 , Courts of First Instance possess general original jurisdiction over cases where the demand exceeds $100, which includes the present action.
2. The provision in Section 5 stating that the penalty may be recovered “as debts of like amount are now recovered in the courts of the United States” refers to the form of the action (civil in nature) and not to an exclusive forum. This interpretation is supported by the U.S. Supreme Court ruling in Lees vs. United States.
3. Section 33 of the same Act defines “the United States” to include its insular possessions, such as the Philippines. Consequently, the phrase “courts of the United States” encompasses courts established under U.S. authority in the Islands.
4. Jurisdiction was not made exclusive to U.S. circuit or district courts, and no law divests the local courts of their general jurisdiction over this statutory cause of action.
The judgment of the Court of First Instance was affirmed.