Title
Barican vs. De los Angeles
Case
G.R. No. L-28979
Decision Date
Jul 31, 1978
Barican contested jurisdiction over jeepneys valued at P11,500; Supreme Court upheld lower court's jurisdiction, dismissing his petition.
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Case Digest (G.R. No. L-28979)

Facts:

  1. Parties Involved:

    • Petitioner: Rafael Barican
    • Respondents: Hon. Judge Walfrido de los Angeles, Melencio C. Cruz, and City Sheriff of Quezon City
  2. Background of the Case:

    • On September 6, 1966, Melencio C. Cruz filed a complaint in the Court of First Instance of Rizal, Quezon City Branch IV, against his wife, Bonifacia Aguilar, and Rafael Barican.
    • Cruz alleged that his wife abandoned their seven children and eloped with Barican, a married man.
    • Cruz sought the recovery of two passenger jeepneys, which he claimed were conjugal properties of his marriage to Bonifacia Aguilar.
  3. Value of the Jeepneys:

    • Cruz stated in his complaint that the two jeepneys were valued at around six thousand pesos.
    • The court issued a writ of replevin after Cruz posted a bond of twelve thousand pesos, and the sheriff seized the jeepneys.
  4. Barican’s Defense:

    • On September 12, 1966, Barican filed a motion to dissolve the writ of replevin, claiming ownership of the jeepneys.
    • He presented two deeds of sale dated January 7 and 21, 1966, showing he purchased the jeepneys for P11,500.
    • Barican argued that Cruz’s claim of ownership was false and fictitious.
  5. Procedural Developments:

    • The respondent judge denied Barican’s motion to dissolve the writ.
    • Barican and Bonifacia Aguilar filed an answer denying Cruz’s claim and counterclaimed for moral and exemplary damages, attorney’s fees, and rental fees for the jeepneys.
    • Their answer was stricken from the record for being filed out of time.
  6. Motion to Annul Proceedings:

    • On November 17, 1967, Barican, through new counsel, filed a motion to annul the proceedings, arguing that the lower court lacked jurisdiction because the value of the jeepneys was only six thousand pesos, as stated in Cruz’s complaint.
    • The lower court denied the motion.
  7. Petition to the Supreme Court:

    • On May 3, 1968, Barican filed a petition for certiorari and prohibition with the Supreme Court, seeking to declare the lower court proceedings void for lack of jurisdiction, restore the jeepneys to him, set aside the registration of one jeepney in Cruz’s name, and enjoin further action in the case.

Issue:

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Ruling:

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Ratio:

  1. Jurisdiction Determined by Pleadings:

    • Jurisdiction over the subject matter is determined by the allegations in the pleadings.
    • Section 44(c) of the Judiciary Law provides that the Court of First Instance has original jurisdiction in cases where the value of the property in controversy exceeds ten thousand pesos.
  2. Barican’s Admission of Value:

    • Barican’s submission of the deeds of sale, showing he purchased the jeepneys for P11,500, refuted his own argument that the value of the property was only six thousand pesos.
    • This admission established that the value of the property was within the jurisdiction of the lower court.
  3. Effect of Counterclaim:

    • The counterclaim filed by Barican and Bonifacia Aguilar did not affect the court’s jurisdiction, as the value of the property in controversy was already within the court’s jurisdiction.
  4. Precedents Cited:

    • The Court cited The Good Development Corporation vs. Tutaan and Carpena vs. Manalo to support its ruling on jurisdiction and the effect of counterclaims.

Conclusion:

The Supreme Court ruled that the lower court had jurisdiction over the case because the value of the jeepneys exceeded ten thousand pesos. Barican’s petition was dismissed, and the writ of preliminary injunction was dissolved. Costs were imposed against Barican.


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