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
Case Digest (G.R. No. L-6903)
Facts:
The case of Despo v. Sta. Maria involves a detainer case in the Municipal Court of Manila. The petitioner, Librada Proceso Despo, was sued by Cristeto Reyes for ejectment. Despo filed an amended answer denying the allegations and filed a counterclaim for damages. The counterclaim consisted of five causes of action, including alleged improvements, moral damages, compensatory damages, exemplary damages, and attorney's fees, amounting to a total of P6,000. Reyes moved for the dismissal of the counterclaim, arguing that the total amount exceeded the jurisdiction of the Municipal Court. The Municipal Court granted the motion and dismissed the counterclaim. Despo then filed a petition for certiorari in the Court of First Instance of Manila, which granted the petition and ordered the Municipal Court to proceed with the hearing of the case, including the counterclaim. Reyes appealed to the Supreme Court.
Issue:
The main issue in this case is whether the Municipal Court had jurisdiction over Despo's counterclaim.
Ruling:
The Supreme Court ruled that the Municipa...