Title
Salas vs. Santiago
Case
G.R. No. L-17090
Decision Date
Mar 30, 1963
Author Pierre L. Salas sued over unauthorized film adaptation of his story "Ifugao," claiming authorship and damages; case certified to Court of Appeals due to jurisdictional limits.

Case Summary (G.R. No. L-17090)

Complaint and Counterclaims

Salas filed a complaint on July 15, 1954, in the Court of First Instance of Pampanga, seeking to claim damages totaling P100,000.00 plus interest and P5,000.00 for attorney's fees. The defendants responded with several counterclaims. Premiere Productions, Inc. denied involvement in the film’s production and counterclaimed for P12,000.00 as attorney's fees. Cornelio Hermoso acknowledged that he produced the film with knowledge of Cirio H. Santiago’s authorship, counterclaiming for P2,000.00 in attorney's fees. Cirio H. Santiago, assisted by his guardian due to his minority, asserted his authorship of the story and demanded P10,000.00 for moral damages along with P2,000.00 for attorney's fees.

Court Proceedings and Initial Rulings

During the trial, it was established that Ciriaco A. Santiago, a defendant who passed away during the proceedings, was substituted by his widow as the guardian for the minor Santiago. The court ultimately ruled in favor of Salas, recognizing him as the legitimate author of "Ifugao." The court ordered the defendants to pay Salas a total of P1,500.00 as compensatory damages, alongside P5,000.00 as moral and exemplary damages, plus P1,000.00 for attorney's fees, which was later increased to P3,000.00.

Appeals and Jurisdiction Issues

Both parties appealed the lower court's decision, with the defendants appealing to the Court of Appeals and Salas appealing to the Supreme Court. The lower court subsequently forwarded both appeals and all evidence presented for consideration. However, the amounts involved in the appeals did not exceed P200,000.00, which is the threshold for jurisdiction in the Supr

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