Case Summary (G.R. No. 167812)
Factual Background
On October 25, 1976, Atty. Lorenzo C. Gella executed a document appointing Severino Cabrera, the husband of Araceli and father of Arnel, as the administrator of his real properties located in San Jose, Antique. Following Severino's death in 1991, Araceli and Arnel, with the respondents' consent, took over the administration of the properties, with the understanding that they would receive a commission of five percent of the properties' purchase price as compensation. A conflict arose when the respondents appointed Erlinda VeAegas as the new administrator of the properties, leading the petitioners to file a complaint on September 3, 2001, against the respondents for collection of agent's compensation, commission, and damages.
Ruling of the Regional Trial Court
In response to the petitioners' complaint, the respondents filed a Motion to Dismiss, arguing lack of jurisdiction based on the jurisdictional amount, failure to state a cause of action, and lack of legal capacity for the petitioners to sue on behalf of all heirs. The Regional Trial Court found that the petitioners’ claim, based on the valuation of the property and the claimed commission, did not exceed the jurisdictional threshold of P200,000 as required. Consequently, the RTC granted the Motion to Dismiss, prompting the petitioners to appeal to the Court of Appeals.
Ruling of the Court of Appeals
The Court of Appeals dismissed the appeal filed by the petitioners, affirming the RTC's decision. The CA ruled that the complaint was primarily for the collection of a sum of money, which is capable of pecuniary estimation. Furthermore, the CA concluded that the petitioners failed to demonstrate a cause of action or prove their legal authority to represent the other heirs of Severino. The appellate court deemed that the claims made exhibited no error warranting the RTC's original ruling.
Issues Presented
The primary issues at hand include whether the Court of Appeals erred in affirming the RTC's findings regarding its lack of jurisdiction, the absence of a cause of action, and whether Araceli and Arnel had the capacity to sue on behalf of Severino's other heirs.
Arguments of the Petitioners
The petitioners contended that the RTC mistakenly relied on the respondents’ arguments without an independent assessment and argued that their claim fell within the RTC's jurisdiction due to its incapacity for pecuniary estimation and the valuation related to real property. They also asserted that their compensation claims should include damages, thus meeting the jurisdictional requirement.
Arguments of the Respondents
The respondents countered that the petitioners’ request amounted to a specific sum of money that fell below the jurisdictional amount of P200,000 for RTCs outside of Metro Manila. They maintained that the claims for damages were incidental and should not contribute to the computation of the jurisdictional limit. Furthermore, they ar
...continue readingCase Syllabus (G.R. No. 167812)
Case Background
- This case revolves around a Petition for Review on Certiorari filed by Araceli J. Cabrera and Arnel Cabrera, along with the heirs of Severino Cabrera, against several respondents including Angela G. Francisco and others.
- The core issue stems from the dismissal of their Complaint for Collection of Agent’s Compensation, Commission, and Damages by the Regional Trial Court (RTC) and its subsequent affirmation by the Court of Appeals (CA).
Factual Antecedents
- On October 25, 1976, Atty. Lorenzo C. Gella appointed Severino Cabrera as the administrator of his real properties in San Jose, Antique, covering approximately 24 hectares, specifically Lot No. 1782-B.
- Following Severino's death in 1991, Araceli and Arnel, with the respondents' consent, continued managing the properties and were promised a 5% commission on the sale price for their services.
- A dispute arose when the respondents appointed a real estate broker as the new administratrix and dismissed Araceli and Arnel from their roles.
- Petitioners filed a Complaint on September 3, 2001, demanding their commission and damages, but respondents sought to dismiss the case on various grounds.
Ruling of the Regional Trial Court (RTC)
- The RTC granted the respondents' Motion to Dismiss based on:
- Lack of jurisdiction due to the amount in controversy being below the jurisdictional threshold of P200,000.
- Failure to state a cause of action as the right to commission was deemed