GR L 5834; (June, 1953) (Digest)
G.R. No. L-5834; June 30, 1953
ISAGANI GALANG, plaintiff-appellee, vs. JUANA PANGAN VDA. DE REYES, defendant-appellant.
FACTS
The plaintiff, Isagani Galang, commenced an action in the Court of First Instance of Negros Occidental to recover the sum of P1,562.84 plus legal interest, attorney’s fees, and costs. The defendant, Juana Pangan Vda. de Reyes, and her counsel, who lived in Manila, were absent from the trial. Judgment was rendered in favor of the plaintiff for the principal amount and interest, but not for attorney’s fees. The defendant filed a motion for reconsideration, alleging that the court lacked jurisdiction over the subject matter, that her absence was due to sudden illness, and that she had a good defense. The trial court denied this motion without addressing the jurisdictional issue raised. The defendant appealed, reiterating these grounds.
ISSUE
Whether the Court of First Instance had jurisdiction to try and decide the case, given that the amount demanded (P1,562.84, exclusive of interest and costs) fell within the exclusive original jurisdiction of the justice of the peace or municipal court under Section 88 of the Judiciary Act of 1948, which was already in effect when the case was filed.
RULING
The Supreme Court reversed the decision of the trial court. It held that the Court of First Instance lacked jurisdiction over the case. Section 88 of the Judiciary Act of 1948, approved on June 18, 1948, granted exclusive original jurisdiction to justices of the peace and municipal judges in civil actions where the demand does not exceed two thousand pesos, exclusive of interest and costs. Since this case was commenced on September 15, 1948, after the Act’s approval, and the amount demanded was only P1,562.84 (below the P2,000 threshold), the Court of First Instance had no authority to adjudicate the matter. The Supreme Court found no legislative intent for the Act to apply retrospectively to causes of action that had accrued but were not yet sued upon before its passage. Consequently, the trial court should have dismissed the case for lack of jurisdiction.