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, while working as a conductor for Batangas Transportation Co.’s bus, was shot and killed by a passenger, Modesto Garcia, 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’s manager that under the Workmen’s Compensation Act, the deceased’s dependents were entitled to P3,120, and thus the balance of P1,470 should be paid. The manager refused payment. 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 the action was not filed in the proper venue (Article 1, paragraph b, Rule 8). The Justice of the Peace Court granted the motion to dismiss, and the Court of First Instance of Lipa City confirmed the dismissal order. The plaintiffs appealed, contending the court erred in declaring the action was improperly filed in the Justice of the Peace Court of Tanauan.

ISSUE

Whether the Justice of the Peace Court of Tanauan, Batangas, had territorial jurisdiction to try the civil action for workmen’s compensation filed by the plaintiffs against the Batangas Transportation Company.

RULING

The Supreme Court affirmed the order of dismissal. The Court held that while Republic Act No. 296 (The Judiciary Act of 1948) increased the jurisdictional amount for civil cases in justice of the peace and municipal courts from P200 to P2,000 (Article 88), this amendment pertained only to jurisdiction over the subject matter and did not alter the rules on territorial jurisdiction. The territorial jurisdiction of a justice of the peace is co-extensive with the municipality, and civil actions (with specific exceptions not applicable here) must be instituted in the municipality where the defendant resides or may be found, as provided by Act No. 1862 and Rule 4, Section 2 of the Rules of Court. The plaintiffs’ action, being based on the Workmen’s Compensation Act and not on a contract, should have been initiated in the Justice of the Peace Court where the defendant corporation could be summoned, which is San Pablo City, the location of its legal residence or central office, and not in Tanauan where the incident occurred. The Court found no incompatibility between Article 88 of Republic Act No. 296 and Rule 4, Section 2; the first governs the amount in controversy, and the second determines the proper venue. The intention of Congress to amend the venue rules was not evident from the law’s language. Jurisdiction of inferior courts cannot be extended by doubtful deductions but only by express legal provision. The defendant timely objected to the venue, and the Justice of the Peace Court of Tanauan did not acquire jurisdiction over its person. The dismissal order was confirmed with costs against the appellants.