Title
Arroz vs. Alojado
Case
G.R. No. L-22153
Decision Date
Mar 31, 1967
The Supreme Court ruled that lower courts lack jurisdiction over non-pecuniary matters, reinstating a land conveyance complaint for further proceedings.
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Case Digest (G.R. No. L-22153)

Facts:

  • Alfredo Arroz is the plaintiff-appellant; Joaquina A. Alojado and others are the defendants-appellees.
  • The events occurred in Brooke's Point, Palawan, on November 10, 1961.
  • A contract was made for the sale of a parcel of land for P1,500, documented in a Memorandum of Agreement of Sale.
  • The agreement stipulated that if the defendant did not return the amount within a specified period, the land would be considered sold to the plaintiff.
  • The defendant had 15 days after November 30, 1961, to redeem the land but failed to do so by December 15, 1961.
  • The plaintiff made several demands for the land's conveyance, including a formal letter on January 4, 1962, which the defendant received.
  • Instead of complying, the defendant deposited P1,530 with the Municipal Treasurer, claiming it fulfilled the obligation.
  • The plaintiff filed a complaint in the Court of First Instance of Palawan for specific performance and declared the deposit illegal.
  • The lower court dismissed the complaint, stating it fell under the jurisdiction of the Justice of the Peace Court.
  • The plaintiff appealed, arguing that the Court of First Instance had jurisdiction due to the nature of the complaint.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court ruled in favor of the plaintiff-appellant, Alfredo Arroz.
  • The order of dismissal by the lower court was set aside.
  • The case was remanded to the court ...(Unlock)

Ratio:

  • The Supreme Court's decision was based on the interpretation of jurisdiction as defined by the Judiciary Act.
  • The Court emphasized that the complaint sought specific performance of a contractual obligation, not merely a monetary claim.
  • Previous jurisprudence, particularly Manufacturer's Distributors, Inc. v. Yu Siu Liong, was referenced, establishing that refusal to perf...continue reading

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