G.R. No. L-4803 February 20, 1952
PRESCILLA MENDOZA VDA. DE TENORIO Y OTROS, demandantes-appelantes, vs. BATANGAS TRANSPORTATION CO., demandante-apelada.

FACTS

On April 26, 1949, Modesto Tenorio, a bus conductor for Batangas Transportation Co., was shot and killed by a passenger, Modesto Garcia, during an altercation in Barrio Santol, Tanauan, Batangas. On May 17, 1949, the company delivered P1,650 to the widow, Prescilla Mendoza Vda. de Tenorio, who signed a receipt before the Municipal Court of San Pablo City. On November 6, 1949, the Director of Labor informed the company that under the Workmen’s Compensation Act, the deceased’s dependents were entitled to P3,120, and thus should be paid a balance of P1,470. The company refused to pay. The widow and children, represented by the Public Defender, filed a claim for P1,470 plus burial expenses on August 3, 1950, in the Justice of the Peace Court of Tanauan, Batangas. The defendant filed a motion to dismiss, alleging improper venue. The Justice of the Peace Court granted the motion to dismiss, and the Court of First Instance of Lipa City affirmed the dismissal order. The plaintiffs appealed, contending that the action was properly filed in Tanauan, citing Article 88 of the Judiciary Act of 1948 (Republic Act No. 296), which increased the jurisdictional amount for inferior courts.

ISSUE

Whether the Justice of the Peace Court of Tanauan, Batangas, had territorial jurisdiction (venue) over the civil action for workmen’s compensation filed against Batangas Transportation Co., whose legal residence or central office was in San Pablo City.

RULING

No. The order of dismissal is affirmed. The Supreme Court held that while Article 88 of the Judiciary Act of 1948 amended the jurisdictional amount (pecuniary jurisdiction) for justice of the peace and municipal courts from P200 to P2,000, it did not amend the rules on territorial jurisdiction (venue). The rules on venue, specifically Article 2, Rule 4 of the Rules of Court (originating from Act No. 1862), require that personal actions, such as this claim not based on a contract, must be instituted in the municipality where the defendant resides or may be found. Since the defendant company’s legal residence or central office was in San Pablo City, the proper venue was the Justice of the Peace Court of that city, not Tanauan where the incident occurred. The Court reasoned that jurisdiction over the subject matter (based on amount) is distinct from territorial jurisdiction (venue). The amendment did not express or imply an intent to allow filing at the place where the cause of action arose. Jurisdiction of inferior courts cannot be presumed or extended by doubtful inference but must be expressly conferred by law.