Facts:

• The case of Catalino Sevilla et al. vs. Gaudencio Tolentino and Fernando Busuego was decided by the Supreme Court of the Philippines on September 21, 1938.
• Plaintiffs, led by Catalino Sevilla, sought to recall a case erroneously certified and transferred to the Court of Appeals by the Supreme Court clerk.
• The legal context involves Commonwealth Act No. 3, enacted on February 1, 1936, which amended the Revised Administrative Code.
• This act reduced the number of Supreme Court justices and established the Court of Appeals, defining their jurisdictions.
• The Supreme Court's appellate jurisdiction was limited to specific cases, including constitutional questions, tax legality, inferior court jurisdiction, serious criminal cases, and civil cases over twenty-five thousand pesos.
• The Court of Appeals was granted exclusive jurisdiction over all other cases not specified for the Supreme Court.
• The clerk of the Supreme Court certified pending cases to the Court of Appeals, except those already decided.
• Commonwealth Act No. 259, enacted on April 7, 1938, redefined jurisdictional boundaries, allowing the Court of Appeals exclusive jurisdiction over civil cases valued below fifty thousand pesos.
• The case involved a land title dispute valued below fifty thousand pesos, raising factual questions but not jurisdictional or constitutional issues.

Issue:

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Ruling:

• The Supreme Court denied the petition to recall the case from the Court of Appeals.
• The transfer was deemed proper under Commonwealth Act No. 259, which granted exclusive appellate jurisdict...(Unlock)

Ratio:

• The Court's decision was based on the interpretation of Commonwealth Act No. 3 and Commonwealth Act No. 259, which clearly defined the jurisdictions of both courts.
• The Court emphasized that statutes regulating appeal rights are remedial and that jurisdictional changes apply to pending cases when the changes take...continue reading