Case Digest (G.R. No. L-16732)
Facts:
On June 5, 1958, nine residents of the barrio of Mactan in the municipality of Opon, province of Cebu, namely Ramon Augusto, Maria Aying, Silvestra Bancale, Clemencia Igot, Silverio Igot, Filomena Malingen, Maximo Silawan, Maximo Ygoy, and Demetrio Ygoy, initiated a legal action against the members of the Barrio Council of Mactan. The plaintiffs alleged that prior to July 1957, the Barrio Council adopted a resolution requesting the Municipal Council of Opon, the Provincial Board of Cebu, and the Presidential Assistance for Community Development to construct a road through their barrio. The plaintiffs contended that the resolution falsely claimed their consent to grant a right of way over their lands for the road's construction without compensation for the land taken or damages incurred due to the removal or destruction of improvements on their properties. Subsequently, without any expropriation proceedings or judicial orders, workers and bulldozers entered their lands, re...
Case Digest (G.R. No. L-16732)
Facts:
Parties Involved:
- Plaintiffs: Ramon Augusto, Maria Aying, Silvestra Bancale, Clemencia Igot, Silverio Igot, Filomena Malingen, Maximo Silawan, Maximo Ygoy, and Demetrio Ygoy (residents of Barrio Mactan, Opon, Cebu).
- Defendants: Members of the Barrio Council of Mactan.
Background of the Case:
- The Barrio Council of Mactan passed a resolution requesting the construction of a road in the barrio.
- The resolution falsely claimed that the plaintiffs had agreed to grant a right of way on their lands without compensation for the land or damages to improvements.
- Without expropriation proceedings or judicial order, workers and bulldozers entered the plaintiffs' lands, destroying crops and plants, causing actual damages to each plaintiff.
Damages Claimed:
- Actual Damages:
- Ramon Augusto: P150
- Maria Aying: P120
- Silvestra Bancale: P415
- Clemencia Igot: P175
- Silverio Igot: P392
- Filomena Malingen: P142
- Maximo Silawan: P122
- Maximo and Demetrio Ygoy: P350
- Moral Damages: P1,000 each (total of P9,000).
- Attorney’s Fees: 20% of the amount recovered.
- Exemplary Damages: No specific amount stated.
- Actual Damages:
Procedural History:
- Plaintiffs filed a complaint in the Court of First Instance of Cebu.
- Defendants filed a motion to dismiss, arguing that the court lacked jurisdiction because each plaintiff’s claim was less than P2,000.
- The trial court dismissed the complaint for lack of jurisdiction, prompting the plaintiffs to appeal.
- The Court of Appeals certified the appeal to the Supreme Court due to the jurisdictional issue.
Issue:
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Ruling:
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Ratio:
Jurisdictional Rule:
- The Supreme Court reiterated the established rule that in cases involving multiple plaintiffs with separate and distinct claims against a common defendant, the jurisdiction of the court is determined by the amount of each individual claim, not the total sum of all claims.
- This rule applies even if the claims arise from the same transaction or series of transactions and involve the same legal or factual questions.
Legal Basis:
- The Court cited its previous ruling in Cajilig et al. vs. Co (109 Phil. 98), which held that the amount of each separate claim, not the aggregate sum, determines jurisdiction.
- The Court emphasized that this rule prevents the splitting of causes of action and ensures that each claim is adjudicated in the proper court based on its value.
Application to the Case:
- Since each plaintiff’s claim was less than P2,000, the Court of First Instance of Cebu lacked jurisdiction.
- The plaintiffs’ argument that the aggregate claim (P11,347.20) should determine jurisdiction was rejected.
Conclusion:
- The dismissal of the complaint by the trial court was proper, and the appeal was without merit.
- The Supreme Court affirmed the dismissal without costs.