G.R. No. L-16732 - Agusto vs. Abing

On June 5, 1958, in the Court of First Instance of Cebu, nine residents of the barrio of Mactan, municipality of Opon, province of Cebu initiated an action.
The plaintiffs—Ramon Augusto, Maria Aying, Silvestra Bancale, Clemencia Igot, Silverio Igot, Filomena Malingen, Maximo Silawan, Maximo Ygoy, and Demetrio Ygoy—were residents adversely affected by an act involving the construction of a road.
The construction was executed following a resolution by the members of the Barrio Council of Mactan in or before July 1957, which solicited assistance from the Municipal Council of Opon, the Provincial Board of Cebu, and the Presidential Assistance for Community Development.

Plaintiffs contended that the Barrio Council maliciously represented that the plaintiffs had consented to granting a right of way and had waived any claim for damages from the construction of the road.
Without proper expropriation proceedings or judicial order, workers and bulldozers proceeded to build the road on the plaintiffs’ lands, thereby causing significant destruction of crops such as corn, banana, cassava, coconut, and bamboo.
Specific actual damages were claimed by each plaintiff, with amounts ranging from P120 to P415, in addition to:

P1,000 each as moral damages (totaling P9,000 collectively), due to mental anguish and wounded feeling.
Attorney’s fees amounting to 20% on any recovery, besides costs and a request for exemplary damages.

On June 25, 1958, the defendants moved to dismiss the complaint on the ground that the Court of First Instance of Cebu lacked jurisdiction since the claim of each plaintiff was less than the then-required minimum of P2,000 (later interpreted to be more than P5,000).
The plaintiffs objected to the motion to dismiss on July 12, 1958.
On August 12, 1958, the trial court issued an order dismissing the complaint for want of jurisdiction, though without prejudice to filing it in the proper court and without imposing costs.
The plaintiffs appealed the order, and the Court of Appeals later certified the appeal to the Supreme Court since the case raised a substantial jurisdictional issue on the pleadings.

The central issue is whether, when several plaintiffs sue a common defendant arising from the same transaction or series of transactions, jurisdiction should be determined by:

Argued that the aggregate claim totaling P11,347.20 (comprising P1,956 in actual damages, P391.20 as attorney’s fees, and P9,000 in moral damages) should serve as the basis for jurisdiction.
Contended that as their consolidated action cannot be partitioned, the total claim should meet the jurisdictional threshold.

Maintained that the jurisdictional test must consider the minimum amount required for each separate claim, not the sum total of all claims filed.