GR L 7112; (May, 1955) (Digest)
G.R. No. L-7112; May 21, 1955
TOMAS Q. SORIANO, plaintiff-appellee, vs. F. R. OMILA, defendant-appellant.
FACTS
Plaintiff Tomas Q. Soriano filed an action in the Court of First Instance to recover from defendant F. R. Omila: (1) P300 on a promissory note; (2) P700 on another promissory note; (3) P3,000 as moral damages for derogatory remarks in a letter; and (4) P600 as attorney’s fees. In his answer, defendant alleged payment of the promissory notes and that the remarks were not ill-motivated, and he counterclaimed for commissions and damages. Defendant failed to appear at the hearing, and the court, after hearing plaintiff’s evidence, rendered judgment in favor of plaintiff for P300 and P700 (first and second causes), but dismissed the claims for moral damages and attorney’s fees for lack of sufficient evidence. Upon notification, defendant filed a motion for reconsideration, alleging that the Court of First Instance lacked jurisdiction over the subject matter of the first, second, and fourth causes of action. The motion was denied, prompting this direct appeal on purely legal questions.
ISSUE
Whether the Court of First Instance had jurisdiction over the subject matter of the action, considering the amounts demanded in the separate causes of action.
RULING
Yes, the Court of First Instance had jurisdiction. The jurisdiction of courts in the Philippines is determined by “the amount of the demand,” not by the “amount in controversy” as in some foreign jurisdictions. Under the Judiciary Act of 1948, Courts of First Instance have original jurisdiction where the demand exceeds two thousand pesos, exclusive of interest. When a complaint joins multiple causes of action, the jurisdiction is based on the aggregate or total amount of all the demands in the complaint, not on the value of each individual cause of action. Here, the aggregate demand was P4,600 (P300 + P700 + P3,000 + P600), which exceeds the jurisdictional minimum. The claim for P3,000 in moral damages was not fictitious; it was dismissed for insufficient evidence, not for being unfounded. Therefore, the totality of the demand placed the case within the jurisdiction of the Court of First Instance. The appeal was without merit.