G.R. No. 172293 - Cabrera vs. Francisco

On October 25, 1976, Atty. Lorenzo C. Gella executed a private document appointing Severino Cabrera as administrator of all his real properties in San Jose, Antique, which include about 24 hectares of land (Lot No. 1782-B, as evidenced by Transfer Certificate of Title No. T-16987).
After Severino’s death in 1991, petitioners Araceli and Arnel Cabrera assumed the administration of the properties with the consent of the respondents, as they had been instructed to look for potential buyers.

Respondents allegedly promised petitioners a five percent commission of the total purchase price of the properties as compensation for their long-term administration services.
Petitioners introduced Erlinda VeAegas, a real estate broker and President of ESV Marketing and Development Corporation, to respondents; however, a conflict arose when respondents appointed Erlinda as the new administratrix and dismissed petitioners from their role.

On September 3, 2001, petitioners filed a Complaint for Collection of Agent’s Compensation, Commission, and Damages before the Regional Trial Court (RTC) of San Jose, Antique.
The Complaint sought:

Payment in the form of real property equivalent to five percent of Lot No. 1782-B;
Moral damages of ₱100,000.00; and
Attorney’s fees and litigation expenses amounting to ₱100,000.00.

A copy of the tax declaration for Lot No. 1782-B was attached to the Complaint, establishing the property’s market value.

Respondents filed a Motion to Dismiss on grounds including lack of jurisdiction, failure to state a cause of action, and lack of legal capacity of petitioners to sue on behalf of other heirs of Severino Cabrera.
A pivotal jurisdictional argument was based on the computation that five percent of the property’s market value (approximately ₱177,506.60 to ₱177,503.60) fell below the required threshold (exceeding ₱200,000.00 for RTCs outside Metro Manila).
The RTC, after an independent and extensive review of the Complaint and attached documents, granted respondents’ Motion to Dismiss and ruled the case dismissed with costs against petitioners.

Petitioners filed their Notice of Appeal, elevating the records to the Court of Appeals (CA).
The CA, in its Decision dated July 6, 2005, affirmed the RTC’s ruling, emphasizing that:

The Complaint was primarily for the collection of a specific sum of money (commission) and did not involve an interest in a real property;
The alleged claim was quantifiable and below the jurisdictional threshold required; and
There was insufficient evidence to show petitioners had authority to sue on behalf of Severino Cabrera’s other heirs.

A Motion for Reconsideration filed by petitioners (challenging only the jurisdiction issue) was denied by the CA in a Resolution dated April 5, 2006.

Petitioners elevated the case to the Supreme Court to challenge the CA’s affirmance of the RTC’s findings on jurisdiction, the cause of action, and the legal capacity to sue on behalf of the other heirs.
The Supreme Court granted the petition for review only to the extent that it would examine if the CA erred on the issues raised.

Whether the RTC (and by extension the CA) erred in determining that it had no jurisdiction over the subject matter of the case because the monetary claim (5% commission) resulted in an amount below the jurisdictional threshold for courts outside Metro Manila.

Whether the Complaint adequately stated a cause of action by sufficiently alleging the petitioners’ right to commission and compensation, given that no sale of the property had been consummated and hence no purchase price existed upon which to compute the commission.

Whether petitioners, acting also in behalf of the heirs of Severino Cabrera, possessed the legal standing necessary to file the Complaint, particularly considering that the Complaint’s verification and certification of non-forum shopping mentioned only Araceli and Arnel.