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. The plaintiffs, Catalino Sevilla and others, filed a petition seeking to recall a case that had been erroneously certified and transferred to the Court of Appeals by the clerk of the Supreme Court. The legal backdrop of the case involves Commonwealth Act No. 3, which was enacted on February 1, 1936, and amended certain provisions of the Revised Administrative Code. This act reduced the number of justices in the Supreme Court and established the Court of Appeals, delineating their respective jurisdictions. Under this law, the Supreme Court's appellate jurisdiction was limited to specific cases, including those involving constitutional questions, legality of taxes, jurisdiction of inferior courts, criminal cases with severe penalties, and civil cases exceeding a value of twenty-five thousand pesos. The Court of Appeals w...

Facts:

1. Case Background: The case involves Catalino Sevilla et al. (plaintiffs) versus Gaudencio Tolentino (defendant and appellant) and Fernando Busuego (defendant and appellee). The petitioners sought to recall the case from the Court of Appeals, claiming it was erroneously certified and transferred by the clerk of the Supreme Court.
2. Jurisdictional Context: Commonwealth Act No. 3, effective February 1, 1936, amended the Revised Administrative Code by reducing the number of Supreme Court justices and creating the Court of Appeals, defining their respective jurisdictions. The Supreme Court's appellate jurisdiction was limited to specific cases, while the Court of Appeals was given exclusive jurisdiction over all other cases.
3. Transfer of Cases: Under Section 145-0 of Commonwealth Act No. 3, pending cases in the Supreme Court that corresponded to the Court of Appeals' jurisdiction were to be certified to the Court of Appeals, provided they had not been heard on argument or submitted for decision.
4. Subsequent Legislation: Commonwealth Act No. 259, approved on April 7, 1938, redefined the jurisdictions of the Supreme Court and the Court of Appeals. Under this Act, civil cases involving values not exceeding fifty thousand pesos or real estate of similar value were appealable exclusively to the Court of Appeals.
5. Case Specifics: The present case involves the title to a piece of land valued below fifty thousand pesos. No constitutional issues or questions about the lower court's jurisdiction were raised.

Issue:

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Ruling:

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Ratio:

1. Statutory Interpretation: Statutes regulating the right of appeal are remedial in nature. Changes in appellate jurisdiction apply to cases pending at the time of the change, unless restricted by law.
2. Transitory Nature of Section 145-0: The provision in Section 145-0 of Commonwealth Act No. 3 was intended to address a specific situation—the transfer of pending cases to the Court of Appeals upon its organization. It did not confer continuing authority on the clerk of the Supreme Court to certify cases after the enactment of Commonwealth Act No. 259.
3. Jurisdiction Under Commonwealth Act No. 259: The case fell within the exclusive appellate jurisdiction of the Court of Appeals under Commonwealth Act No. 259, as it involved the title to land valued below fifty thousand pesos and raised no constitutional or jurisdictional issues.