G.R. No. L-22294 January 12, 1968
DIONISIA PARAMI VDA. DE CABASAG, petitioner, vs. AMADOR P. SU, RICARDO BORBON, ROQUE L. SU SR., TIMOTEO LOZADA, MARIA (NIEVES) LOZADA VDA. DE SU and HONORABLE ALFREDO CATOLICO, respondents.

FACTS

Petitioner Dionisia Parami Vda. de Cabasag filed a complaint in the Court of First Instance (CFI) of Misamis Occidental for “Recovery of Actual Damages of Real Property” against the private respondents. She alleged three causes of action: (1) that the defendants, through deceit, induced her and her late illiterate husband to thumbmark a document falsely represented as an acknowledgment of debt, which was actually an absolute deed of sale for their coconut land covered by a homestead application; that the purported price of P11,000 was never received; and that defendants took possession and reaped the fruits, causing damages of P57,000; (2) that the defendants demolished her house on the land, valued at P10,000; and (3) that she suffered moral damages of P50,000 and was entitled to attorney’s fees. The complaint prayed for the declaration of nullity of the deed of sale and recovery of total damages and fees amounting to P122,000. The defendants filed answers with a counterclaim for P105,000. The CFI, presided by Judge Alfredo Catolico, issued an order remanding the case to the Justice of the Peace Court of Sapang Dalaga, citing Republic Act No. 3828 regarding the original jurisdiction of municipal courts. Petitioner’s motion for reconsideration was denied.

ISSUE

Whether the Court of First Instance erred in remanding the case to the Justice of the Peace (Municipal) Court, thereby declining to exercise its jurisdiction.

RULING

Yes, the CFI’s order of remand was erroneous and indefensible. The Supreme Court granted the petition for certiorari. The Court held that Republic Act No. 3828 merely increased the civil jurisdiction of municipal courts to cases involving not more than P10,000, which is only a tenth of the damages claimed in the complaint (P122,000) and the counterclaim (P105,000). Furthermore, the complaint prayed for the nullification of a deed of sale and the consequent recovery of a piece of land, which placed the case within the exclusive original jurisdiction of the Court of First Instance, as inferior courts could only pass upon title to land incidentally in forcible entry and detainer suits. The order of the lower court was annulled and set aside, and the case was remanded to the CFI for further proceedings. Costs were imposed on the private respondents.