G.R. No. L-21888; June 26, 1967
Basilia F. Vda. de Zaldarriaga, in her capacity as Judicial Administratrix of the Intestate Estate of her late husband, Jose Zaldarriaga, plaintiff-appellee, vs. Pedro Zaldarriaga, deceased, substituted by Consuelo T. Vda. de Zaldarriaga, as Judicial Administratrix of his Intestate Estate, et al., defendants-appellants.

FACTS

The parties are co-owners of a parcel of land with an assessed value of P137,800. The plaintiff, representing the estate of Jose Zaldarriaga, owns an undivided 1/8 share. The defendants own the remaining 7/8 shares and have been in possession of the land for 34 years, cultivating 7/8 of it and leaving 1/8 uncultivated. The plaintiff demanded a specific portion of the property and an accounting of produce, rentals, and profits amounting to P202,302. The trial court upheld her right to 1/8 of the hacienda, awarded her share of produce, back rentals, and profits plus damages totaling P139,586, and ordered that her 1/8 share be taken from the cultivated portion. The defendants appealed, contesting the award and the court order. This is the second time the case is before the Supreme Court; the first appeal was remanded for partition proceedings. The present appeal involves 22 assigned errors, only 5 of which involve pure questions of law, with the rest involving factual questions or mixed questions of fact and law.

ISSUE

Whether the Supreme Court has appellate jurisdiction over the case, considering the value in controversy and the nature of the questions raised on appeal.

RULING

The Supreme Court does not have jurisdiction and certified the appeal to the Court of Appeals. The Court’s exclusive appellate jurisdiction, under Section 17(3), paragraph 5 of Republic Act No. 296 (as amended), covers civil cases where the value in controversy exceeds P200,000 or where the title or possession of real estate exceeding P200,000 in value is involved. Here, the plaintiff did not appeal, so the award of P139,586 represents the value in controversy for the appeal. While title to real estate is involved, the dispute concerns only a 1/8 portion valued at P17,300 (1/8 of P137,800). The total value in controversy is therefore P156,886 (P139,586 + P17,300), which does not exceed P200,000. Furthermore, most of the assigned errors involve factual questions, over which the Court of Appeals has jurisdiction. Citing Imperial v. Manila Times, the Court held that where the awarded amount is below the jurisdictional threshold and the appeal primarily involves factual issues, the case falls within the jurisdiction of the Court of Appeals.