Title
Despo vs. Sta. Maria
Case
G.R. No. L-6903
Decision Date
Jan 31, 1956
A detainer case in the Municipal Court of Manila involving a counterclaim for damages is dismissed by the Supreme Court due to exceeding the jurisdiction of the Municipal Court, as the total amount demanded in the counterclaim exceeded P2,000.
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Case Digest (G.R. No. L-6903)

Facts:

  • The case involves a detainer (ejectment) case filed by Cristeto Reyes against Librada Proceso Despo in the Municipal Court of Manila.
  • Despo filed an amended answer denying the allegations and filed a counterclaim for the recovery of a total sum of P6,000 under five causes of action.
  • The causes of action include alleged improvements introduced by Despo in the premises, moral damages suffered due to the untimely removal and demolition of the apartment, compensatory damages for the demolition of her shop, exemplary damages due to alleged fraudulent dealings, and attorney's fees.
  • Reyes moved for the dismissal of Despo's counterclaim, arguing that the total amount claimed exceeded the jurisdiction of the Municipal Court.
  • The Municipal Court granted the motion and dismissed the counterclaim.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court ruled in favor of Reyes and held that the Municipal Court did not have jurisdic...(Unlock)

Ratio:

  • The Court cited the recent case of Soriano v. Omila, which established that the jurisdiction of a court is determined by the total amount demanded in all causes of action, not the value of each individual cause of action.
  • Since the total amount demanded in Despo's counterclaim exceeded P2,000, it fell within the jurisdiction of the Court of First Instance, not the Municipal Court.
  • The Court explained that since all five items of damages demanded in Despo's counterclaim arose out of one and the same transaction, she cannot divide or split her cause of action into several claims for the purpose of bringing the case within the jurisdiction of the Municipal Court.
  • The totality of the amounts demanded in the counterclaim determines the jurisdiction, and since it exceeded P2,000, it must be filed in the Court of First...continue reading

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