G.R. No. L-6091 December 10, 1954
ALEJANDRO F. FERNANDEZ, plaintiff-appellee, vs. ILUMINADA GALA-SISON, defendant-appellant.

FACTS

The plaintiff, Alejandro F. Fernandez, a licensed surveyor, filed a complaint in the Court of First Instance of Manila. He alleged that he was contracted by Socorro Manalo de Gala, Severino de Gala, and Iluminada de Gala-Sison to survey eleven parcels of land from the intestate estate of the late Generoso de Gala for the sum of P4,280. He claimed that the defendants paid only P1,280, leaving a balance of P2,950, and that he was entitled to an additional 25% of the amount due as attorney’s fees (P737.50), for a total claim of P3,687.50. During the trial, the parties entered into a stipulation of facts. They agreed that the total amount for the survey was P2,164.50, and that the amount paid was P1,280, leaving a balance of P884.50 due to the plaintiff. The trial court rendered judgment, ordering defendant Iluminada de Gala-Sison to pay the plaintiff the amount of P163 with legal interest and costs, absolving her regarding the claim for attorney’s fees, and dismissing the complaint as to Socorro Manalo de Gala and Severino de Gala. The defendant appealed, contending that the Court of First Instance lost jurisdiction over the case when, by stipulation of facts, the obligation was reduced to P884.50, which amount was within the exclusive original jurisdiction of the municipal court.

ISSUE

Whether the Court of First Instance lost its jurisdiction over the case after the parties, during trial, stipulated that the amount due to the plaintiff was only P884.50, which was below the jurisdictional amount for the court.

RULING

The Supreme Court ruled that the Court of First Instance did not lose jurisdiction. The jurisdiction of a court in a civil case is determined by the allegations of the complaint, not by the result of the evidence or by any subsequent reduction of the claim. In this case, the plaintiff’s complaint alleged a claim of P3,687.50, which was within the jurisdiction of the Court of First Instance. The subsequent stipulation reducing the claim to P884.50 did not divest the court of its jurisdiction, which had already attached. The Court rejected the appellant’s theory, stating that such a rule would lead to provisional jurisdiction and create an cumbersome judicial process. The law (Article 88, Act No. 296) refers to “the amount of the demand” to determine jurisdiction, meaning the amount alleged in the complaint. The trial court’s decision ordering payment of P163 (calculated as two-thirds of the agreed fee of P2,164.50, minus the payment made, after finding the plaintiff complied with only two of three contract conditions) was correct. The appealed decision was affirmed, with no pronouncement as to costs in this instance.