G.R. No. L-25589 November 29, 1968
CITY OF LEGAZPI, petitioner, vs. THE HONORABLE ROBERTO ZURBANO, Judge of the CFI of Albay; ORESTES MAGDARAOG, SOCORRO AMADOS, LOURDES ANTIVOLA, RAFAELLA YAN, CARLOS ARJONA, DOLOR BASALLOTE, SR., DOLOR BASALLOTE, JR., and EDWIN BASALLOTE, respondents.

FACTS

Several plaintiffs, including Orestes Magdaraog and others, filed an action for damages in the Court of First Instance of Albay against the City of Legazpi and other defendants. The complaint alleged that on December 4, 1964, a fire truck owned by the City of Legazpi, due to the imprudence of its driver, collided with several vehicles, including passenger bus No. PUB-4628, causing its demolition and injuring passengers. The claims were: Juan Marbella (bus owner) P10,500.00; Orestes Magdaraog P2,500.00; Socorro Amados P4,500.00; Lourdes Antivola P2,500.00; Rafaela Yan P500.00; Carlos Arjona P500.00; Dolor and Edwin Basallote P1,000.00; plus Attorney’s fees of P5,000.00. The City of Legazpi moved to dismiss the complaint for lack of jurisdiction, arguing that the amount demanded by each passenger plaintiff (including a ratable share of attorney’s fees) did not exceed P10,000.00, thus placing their claims within the exclusive original jurisdiction of the Municipal Court under Section 88 of the Judiciary Act. The Court of First Instance overruled the motion, holding it had jurisdiction based on Rule 2, Section 5 of the Rules of Court regarding joinder of causes of action, as applied in prior cases. The City of Legazpi appealed directly to the Supreme Court.

ISSUE

Whether jurisdiction over the claims of the passenger plaintiffs should be determined by the aggregate amount of all their claims or by the amount of each individual claim.

RULING

The Supreme Court ruled in favor of the petitioner, City of Legazpi. Jurisdiction is determined by the amount of each individual claim, not their aggregate. The Court held that Section 88 of the Judiciary Act, as amended, is the controlling statutory provision, which expressly states: “where the claims or causes of action joined in a single complaint are separately owned by or due to different parties, each separate claim shall furnish the jurisdictional test.” The provisions of the Rules of Court on joinder of causes of action and parties are subject to rules regarding jurisdiction and cannot be used to circumvent this statutory prescription, as Congress has the constitutional power to define and apportion jurisdiction. The order of the Court of First Instance was annulled and set aside, except as to the claim of plaintiff Juan Marbella (which exceeded P10,000.00). The Court of First Instance was directed to dismiss the claims of the other plaintiffs, as they were within the jurisdiction of the proper municipal court, though they could be properly joined in a single complaint therein.