GR L 3884; (November, 1951) (Digest)
G.R. No. L-3884 November 29, 1951
INTERNATIONAL COLLEGES, INC., petitioner-appellee, vs. NIEVES ARGONZA, ET AL., respondents-appellants.
FACTS
Twenty-five dismissed teachers of the International Colleges, Inc., a domestic corporation, jointly sued the corporation in the Municipal Court of Manila for unpaid salaries. They alleged they were employed for the entire school year ending April 30, 1949, at specified salaries, but were unjustly dismissed on December 10, 1948, without payment of their due salaries. The aggregate claim was P14,211.13, but no individual claim exceeded P1,300. The defendant moved to dismiss the complaint, contending there was a misjoinder of parties-plaintiff and that the total amount involved exceeded the municipal court’s jurisdiction. The municipal court denied the motion. The defendant then filed a petition for certiorari with the Court of First Instance of Manila. The CFI revoked the municipal court’s order and dismissed the complaint, upholding the defendant’s contention. The plaintiffs appealed, arguing the lower court erred in holding (1) there was a misjoinder of parties-plaintiff and (2) the aggregate amount of the claims, not each individual claim, determined jurisdiction.
ISSUE
1. Whether the joinder of the 25 plaintiffs in a single complaint was proper under the Rules of Court. 2. Whether the jurisdiction of the municipal court is determined by the aggregate amount of all claims or by the amount of each individual claim.
RULING
1. Yes, the joinder was proper. The joinder is authorized under Section 6, Rule 3 of the Rules of Court, which permits joinder when a right to relief exists in favor of all plaintiffs arising out of the same transaction or series of transactions and a common question of law or fact exists. Here, the plaintiffs’ right to relief arose from the same transaction or series of transactions—their mass dismissal by the defendant. A common question of law existed for all plaintiffs. The Supreme Court cited the case of A. Soriano y Cia. vs. Gonzalo M. Jose, et al., which sanctioned a similar joinder of multiple employees suing for a month’s salary in lieu of notice.
2. The jurisdiction of the municipal court is determined by the amount of each individual claim, not the aggregate. The Supreme Court, citing A. Soriano y Cia. and American jurisprudence, held that where several plaintiffs have separate and distinct demands against a defendant, properly joined in a single suit, each separate claim furnishes the jurisdictional test; the claims cannot be aggregated to determine jurisdiction. The Court distinguished this from a case where a single plaintiff alleges several independent causes of action in one complaint, where the aggregate amount determines jurisdiction. The purpose of the permissive joinder rule is to save parties unnecessary work and expense, not to enlarge a court’s jurisdiction based on the amount in controversy. The decision of the Court of First Instance was revoked, and the complaint was ordered reinstated in the Municipal Court of Manila. Costs were awarded against the appellee.