Title
Abon vs. Pablo
Case
G.R. No. L-18096
Decision Date
Jan 31, 1963
Tenants sued owners for unlawful rent increase, seeking refunds; court dismissed due to lack of jurisdiction over individual claims below P5,000.
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Case Digest (G.R. No. L-18096)

Facts:

    Parties Involved

    • Plaintiffs/Applicants:
- Maria Abon, Maria Aldave, Conchita Ang, and fifty others. - Occupants and tenants of different portions of a property. - Amparo E. Pablo and Lily E. Pablo, owners of the property in dispute.

    Background of Tenancy and Rent Increase

    • Location and Nature of the Property:
- The property is situated along Tejeron and Esguerra Streets, Sta. Ana, Manila. - The tenants occupied various portions thereof, each paying an individual monthly rent ranging from P5.00 to P10.00. - After December 31, 1953, the appellees required increased rental payments. - The tenants obliged and paid the increased rents. - Plaintiffs alleged that the increase violated Section 5 of Republic Act 1162, as amended by Republic Acts 1599 and 2342. - The law in question barred owners of landed estates (authorized to be expropriated) in the City of Manila from increasing the rents charged as of December 31, 1953.

    Claims and Relief Sought

    • Monetary Claims:
- Recovery of the excess amounts paid over the December 31, 1953 rents, totaling P6,843.67. - Awarding of exemplary damages calculated at three times the amount of each individual claim. - Compensation for attorney’s fees and such other costs incidental to the case.

    Appellees’ Defense and Argument

    • Grounds for Dismissal:
- Appellees contended that the complaint failed to state a sufficient cause of action. - Asserted that their property, being one hectare in area, was not a “landed estate” within the meaning of Republic Act 1162. - Claimed that the rent increase was lawful as it corresponded with an increase in the land tax assessment of the property. - The appellees argued that the proper venue should be the Municipal Court of Manila because the individual claims did not exceed the requisite amount (P5,000.00) for the Court of First Instance's jurisdiction.

    Procedural History

    • Court of First Instance Decision:
- The trial court dismissed the complaint on two counts: - The appellants elevated the case by appealing from the dismissal order of the Court of First Instance.

Issue:

    Sufficiency of the Cause of Action

    • Whether the facts alleged in the complaint constitute a valid claim against the defendants for the alleged rent increases.
    • Whether the alleged violation of Section 5 of Republic Act 1162, as amended, provides a legal basis for the relief sought by each individual plaintiff.

    Jurisdictional Requirements

    • Determination of whether the Court of First Instance had jurisdiction over the complaint given that the largest individual claim did not exceed the jurisdictional amount of P5,000.00.
    • The applicability of the rule regarding joinder of claims, where each individual claim is treated independently for purposes of the jurisdictional amount even if joined in one consolidated complaint.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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