Title
Abary vs. Agawin
Case
G.R. No. 45028
Decision Date
Nov 25, 1938
Plaintiffs sued defendant for separate loans within jurisdictional limits; lower court erred in dismissing case due to aggregated claims. Supreme Court reversed, remanded for trial.
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Case Digest (G.R. No. 45028)

Facts:

  1. Parties Involved:

    • Plaintiffs-Appellants: Maximo Abary and Victoria Zalameda (spouses).
    • Defendant-Appellee: Fidelino Agawin.
  2. Nature of the Case:

    • The plaintiffs filed a complaint against the defendant in the Court of First Instance of Laguna.
  3. Defendant's Demurrer:

    • The defendant filed a demurrer (a motion to dismiss) on two grounds:
      a. The court lacked jurisdiction because the justice of the peace court, where the case originated, did not have jurisdiction due to the amount claimed.
      b. The complaint did not allege sufficient facts to constitute a cause of action.
  4. Lower Court's Decision:

    • The lower court sustained the demurrer on the first ground (lack of jurisdiction) and dismissed the case after the plaintiffs failed to amend their complaint.
  5. Plaintiffs' Appeal:

    • The plaintiffs appealed, assigning the following errors:
      a. The court erred in sustaining the demurrer after previously overruling it.
      b. The court erred in not rendering judgment in favor of the plaintiffs after overruling the demurrer.
      c. The court erred in dismissing the case and ordering the plaintiffs to pay costs.
  6. Amounts Claimed:

    • The plaintiffs' complaint alleged two independent causes of action:
      a. A loan of P500 obtained by the defendant from the plaintiffs on October 17, 1934.
      b. A loan of P100 obtained by the defendant from plaintiff Victoria Zalameda on October 23, 1934.
  7. Jurisdictional Issue:

    • The defendant argued that the justice of the peace court lacked jurisdiction because the total amount claimed (P600) exceeded its jurisdictional limit.

Issue:

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Ruling:

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Ratio:

  1. Jurisdiction Based on Separate Causes of Action:

    • When a complaint alleges multiple independent causes of action, each within the jurisdictional limit of the court, the amounts should not be aggregated to determine jurisdiction. Each cause of action stands alone for jurisdictional purposes.
  2. Procedure After Overruling a Demurrer:

    • If a demurrer is overruled, the court should wait for the defendant to answer the complaint. If the defendant fails to answer, the plaintiff must present evidence to prove the allegations in the complaint. Judgment cannot be rendered in favor of the plaintiff without evidence.
  3. Reconsideration of Orders:

    • A lower court has the authority to reconsider its orders, provided the case remains within its jurisdiction and there are valid reasons for doing so.
  4. Costs and Dismissal:

    • A case should not be dismissed based on incorrect reasoning, and plaintiffs should not be burdened with costs if the dismissal was unjustified.


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