GR L 23036; (January, 1967) (Digest)
G.R. No. L-23036 January 27, 1967
Beatriz Salon and her husband, Perfecto Esteves, plaintiffs-appellants, vs. Fortunata Figuracion and her husband, defendants-appellees.
FACTS
Beatriz Salon and Perfecto Esteves filed an action for damages based on alleged defamatory imputations against Fortunata Figuracion and her husband in the Court of First Instance of Pangasinan on February 4, 1961. The original complaint demanded P4,990.00 in damages and P1,000 in attorney’s fees. An amended complaint was filed on February 17, 1961, raising the demand to P10,000 in moral damages and P1,000 in attorney’s fees. Defendants filed an answer with a counterclaim on March 15, 1961, and plaintiffs answered the counterclaim on March 23, 1961. On June 22, 1963, Republic Act 3828 took effect, amending the Judiciary Act by increasing the exclusive original jurisdiction of municipal courts to cover civil actions where the demand does not exceed ten thousand pesos (raised from five thousand pesos), exclusive of interests and costs. Subsequently, on February 20, 1964, defendants moved to dismiss the amended complaint, contending that the Court of First Instance had lost jurisdiction because the suit, demanding P10,000, now fell under the exclusive original jurisdiction of the municipal court. The Court of First Instance granted the motion and dismissed the suit for lack of jurisdiction on March 3, 1964. Plaintiffs appealed the order of dismissal.
ISSUE
Whether the Court of First Instance correctly dismissed the case for lack of jurisdiction based on the increased jurisdictional limit under Republic Act 3828, considering the total amount of the demand in the amended complaint.
RULING
The Supreme Court reversed the order of dismissal and remanded the case to the Court of First Instance for further proceedings. The Court held that the amended complaint demanded P10,000 in moral damages and P1,000 in attorney’s fees, totaling P11,000. This aggregate sum is within the original jurisdiction of the Court of First Instance because the amount demanded for attorney’s fees must be included in determining jurisdiction, with only costs and interest being excluded, as established in Carlos vs. P. J. Kiener Construction, Ltd., 100 Phil. 29, and other cited jurisprudence, and in accordance with Section 88 of Republic Act 296 (the Judiciary Act).