Title
Campos Rueda Corp. vs. Sta. Cruz Timber Co., Inc.
Case
G.R. No. L-6884
Decision Date
Mar 21, 1956
Campos Rueda Corp. sued for promissory notes totaling P2,200; courts dismissed due to jurisdictional limits. SC affirmed dismissal, ruling jurisdiction based on aggregate demand, allowing refiling in proper court.
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Case Digest (G.R. No. L-6884)

Facts:

  1. Initial Filing in Court of First Instance: In 1950, Campos Rueda Corporation filed a case in the Court of First Instance of Manila against Sta. Cruz Timber Co. and Alfonso L. Felix to recover the value of two promissory notes dated November 23, 1948, and November 30, 1948, for amounts of P1,125 and P1,075, respectively. The court dismissed the case, holding that the two notes constituted separate causes of action, each involving less than P2,000, and thus fell outside its jurisdiction.

  2. Subsequent Filing in Municipal Court: On February 22, 1952, Campos Rueda Corporation filed another action in the Municipal Court of Manila for the same promissory notes. The Municipal Court dismissed the case, ruling that the consolidated amount of the two notes (P2,200) exceeded its jurisdiction. The Court of First Instance upheld this dismissal on appeal.

  3. Appeal to the Supreme Court: Campos Rueda Corporation appealed directly to the Supreme Court, raising the sole issue of whether the Municipal Court had jurisdiction over the subject matter of the complaint.

Issue:

The primary issue was whether the Municipal Court of Manila had jurisdiction over the case, given that the aggregate amount of the two promissory notes (P2,200) exceeded the jurisdictional limit of P2,000 for municipal courts under the Judiciary Act of 1948.

Ruling:

The Supreme Court affirmed the dismissal of the case by the Court of First Instance, holding that the Municipal Court lacked jurisdiction. The Court ruled that the jurisdiction of a court is determined by the total or aggregate amount demanded in the complaint, not by the value of each individual cause of action. Since the total demand (P2,200) exceeded the jurisdictional limit of the Municipal Court, it could not take cognizance of the case.

Ratio:

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