Case Summary (G.R. No. L-34952)
Factual Background
On October 28, 1998, the Sevilleno sisters filed a complaint for damages in the RTC against the Carilo spouses, seeking P5,000.00 as actual damages, P400,000.00 for moral damages, P10,000.00 for exemplary damages, and P50,000.00 for attorney's fees. The Carilos countered by filing an answer to dismiss the complaint based on a lack of cause of action.
RTC's Dismissal
On March 23, 1999, the RTC, acting motu proprio, dismissed the case, claiming a lack of jurisdiction over the subject matter. The Sevillenos sought reconsideration, which was denied by the RTC in an Order dated May 18, 1999.
Appeal to the Court of Appeals
Following the RTC's denial of the motion for reconsideration, the Sevillenos filed an appeal to the Court of Appeals (CA). However, this appeal was dismissed because it was deemed to be the incorrect mode of appeal, as the issue concerned the jurisdiction of the RTC—a purely legal question.
Applicable Rules on Appeal
Under Section 2, Rule 41 of the 1997 Rules of Civil Procedure, appeals from the RTC to the CA must follow specific modes. The rules distinguish between appeals based on questions of fact, mixed questions, and pure questions of law. Since the matter at hand was strictly about jurisdiction, it fell under the provision that requires such appeals to be directed to the Supreme Court via a petition for review on certiorari under Rule 45.
Misapplication of Appeal Procedure
The Court of Appeals explained that because the fundamental issue was the RTC's jurisdiction—an issue related exclusively to law—the Sevillenos were required to file their appeal with the Supreme Court. By attempting to pursue an ordinary appeal to the CA, they utilized the wrong procedural route.
Rationale for Dismissal
Overall, the appellate court's rationale hinged on the established principle that qu
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Case Overview
- The case involves a petition for review on certiorari filed by Pamela S. Sevilleno and Purita S. Sevilleno (petitioners) against Pacita Carilo and Camelo Carilo (respondents).
- The Supreme Court's ruling is documented in 559 Phil. 789, dated September 14, 2007, under G.R. No. 146454.
Background of the Case
- On October 28, 1998, the petitioners filed a complaint for damages against the respondents in the Regional Trial Court (RTC), Branch 82, Quezon City, under Civil Case No. Q-35895.
- The petitioners sought:
- P5,000.00 as actual damages
- P400,000.00 as moral damages
- P10,000.00 as exemplary damages
- P50,000.00 for attorney's fees
- The respondents filed an answer with a compulsory counterclaim, requesting the dismissal of the complaint for lack of cause of action.
RTC Decision
- On March 23, 1999, the RTC issued an Order dismissing the case, citing lack of jurisdiction over the subject matter.
- The petitioners filed a motion for reconsideration, which the RTC denied in an Order dated May 18, 1999.
Appeal to the Court of Appeals
- The petitioners appealed to the Court of Appeals, which subsequently dismissed the appeal, determining it was the wrong