G.R. No. 171182 - University of the Philippines vs. Dizon

The case is an appeal from the decision of the Court of First Instance of Zamboanga, which had reversed a verdict rendered by a referee in a cockfight dispute.
The matter involved combined bets amounting to P860.00, which were deposited pending the outcome of the suit.
Initially, a complaint was filed with the municipal court; however, it was dismissed for lack of jurisdiction due to the amount involved.
Subsequently, the action was instituted in the Court of First Instance, where a motion to dismiss again questioned the court’s jurisdiction—but on different grounds.

The central issue involved conflicting laws: the Spanish Royal Decree (the “Reglamentos Sobre Galleras”) and Act No. 136, as amended by later statutes.
It was argued that decisions of referees in cockfights were appealable only to the justice of the peace, as provided by articles 76 and 77 of the Spanish Royal Decree.
The court, however, noted that the Royal Decree had been repealed insofar as it conflicted with existing statutes.
Act No. 136, particularly Section 57, provided that courts of first instance have appellate jurisdiction over cases arising in justices' and inferior courts within their respective provinces, thereby abrogating the prior law.

On the merits, both parties agreed that after several clashes, the defendants’ rooster ("Malatuba") was mortally wounded, while the plaintiff’s rooster ("Mayahin") remained unscathed.
The dispute centered on the interpretation of what constituted a win in the context of cockfighting when one bird was wounded.
The plaintiff contended that his rooster should have been declared the winner since it was not wounded, whereas the defendants maintained that the evidence supported the referee’s decision awarding victory to their rooster.

Admission by the defendants’ witnesses that multiple encounters occurred between the roosters prior to the final act.
Testimony that "Malatuba" was gravely wounded, yet still on its feet when the referee declared it the winner, while "Mayahin" displayed signs of retreat.

Although he argued that the defendant’s rooster was dead when picked up by the referee, his own testimony inadvertently admitted that his rooster had fled.
Testimonies from plaintiff's witnesses contained contradictory elements regarding the condition and comportment of the roosters before the decision was rendered.

Defendants’ evidence was reported to be more coherent, logical, and straightforward, with corroborative endorsements from witnesses such as Mariano Hernandez (the referee) and Suki Singhoe (municipal policeman).

The Court noted that Act No. 136, including its amendments (sections 56, 57, and 68), set the threshold for jurisdiction based on the amount in controversy, thus extending the appellate reach to decisions rendered by justices of the peace.
The provision in the Royal Decree requiring action within three days from the date of the decision was deemed superseded by current statutes governing prescription and limitations of actions under Act No. 190.

Whether the Court of First Instance had proper jurisdiction to hear the cockfight dispute despite the conflicting provisions between the Spanish Royal Decree and Act No. 136.
Whether the appellate jurisdiction over decisions rendered by justices of the peace, as previously provided in the Royal Decree, was effectively replaced by the current statutory scheme.

Whether the conflicting testimonies regarding the state and behavior of the roosters at the climax of the fight warranted a reversal of the referee’s decision.
To what extent the incoherence and vagueness in the plaintiff’s evidence compared to the more unified and corroborated defendants’ evidence should influence the final determination.

Whether the action was subject to the limitations prescribed by Act No. 190, in contrast to the obsolete prescription period mentioned in the Royal Decree.