GR L 22153; (March, 1967) (Digest)
G.R. No. L-22153 March 31, 1967
ALFREDO ARROZ, plaintiff-appellant, vs. JOAQUINA A. ALOJADO, ET AL., defendants-appellees.
FACTS
Plaintiff Alfredo Arroz filed a complaint in the Court of First Instance of Palawan against defendant Joaquina A. Alojado, et al., seeking specific performance of a Memorandum of Agreement dated November 10, 1961. The agreement stated that the defendant received P1,500.00 from the plaintiff, with a portion of her residential lot given as collateral. It stipulated that if the defendant failed to return the amount by November 30, 1961, the land would be considered as sold, but she would be given another 15 days to redeem it. The defendant exercised her right to redeem on November 30, 1961, extending the redemption period to December 15, 1961. The defendant failed to redeem by December 15, 1961. The plaintiff demanded conveyance of the land, but the defendant refused. The defendant subsequently deposited P1,530.00 with the Municipal Treasurer. The complaint prayed for: (1) conveyance of the land by deed; (2) a declaration that the deposit was illegal and void; and (3) payment of P1,000.00 in damages. The Court of First Instance dismissed the complaint on the ground that it properly fell under the jurisdiction of the Justice of the Peace Court (Municipal Court). The plaintiff appealed, contending that the Court of First Instance had jurisdiction because the action was for specific performance.
ISSUE
Whether the Court of First Instance has jurisdiction over the complaint, which seeks specific performance of an obligation (conveyance of land) and a declaration on the validity of a monetary deposit, or whether the case falls under the jurisdiction of the Justice of the Peace/Municipal Court.
RULING
The Supreme Court set aside the order of dismissal and remanded the case to the Court of First Instance. It ruled that the Court of First Instance has jurisdiction because the subject matter of the litigation is not capable of pecuniary estimation. The complaint primarily seeks specific performance—the conveyance of the land—and a declaration on the legality of the monetary deposit. These issues cannot be assessed in terms of money. Under Section 88 of the Judiciary Act, as amended, the jurisdiction of a Justice of the Peace/Municipal Court does not extend to civil actions where the subject of litigation is not capable of pecuniary estimation. The fact that the agreement involved a loan of P1,500.00 does not convert the action into a money claim, as the plaintiff’s demand is for the delivery of the property, not payment of the loan. The claim for damages is merely incidental to the main action for specific performance. Therefore, the case is within the original jurisdiction of the Court of First Instance.