GR L 7020; (June, 1954) (Digest)
G.R. No. L-7020 June 30, 1954
ALICIA GO, ET AL., plaintiffs-appellees, vs. ALBERTO GO, ET AL., defendants-appellants.
FACTS
On December 18, 1951, plaintiffs-appellees filed an action for ejectment (recovery of possession) and damages in the Municipal Court of Manila against defendants-appellants. The defendants, in their answer, set up a counterclaim divided into three causes of action: (1) P2,000 for the value of furniture and equipment allegedly taken by plaintiffs; (2) P1,000 for expenses due to the falsity of the complaint; and (3) P500 as attorney’s fees. The municipal court ruled for the plaintiffs on the ejectment but denied both parties’ claims for damages as being beyond its jurisdiction. Defendants appealed to the Court of First Instance (CFI). Plaintiffs then filed an amended complaint, and defendants reiterated their counterclaim. Plaintiffs moved to dismiss the counterclaim, arguing that its aggregate amount (P3,500) was beyond the municipal court’s jurisdiction and thus the CFI could not act on it in its appellate capacity. The CFI granted the motion to dismiss. Hence, this appeal.
ISSUE
Whether the counterclaim was within the jurisdiction of the Municipal Court, and consequently, whether the Court of First Instance has appellate jurisdiction over it. Specifically, whether jurisdiction is determined by the amount of each separate cause of action within the counterclaim or by the aggregate amount of all causes of action.
RULING
The Supreme Court set aside the order of dismissal. The counterclaim was within the municipal court’s jurisdiction. The test for jurisdiction is the amount of each separate cause of action, not the aggregate sum, when the causes of action arise from distinct transactions. Here, the three causes of action were distinct: the first (P2,000) arose from the alleged unlawful taking of property, while the second and third (P1,000 and P500) arose from the allegedly unlawful institution of the ejectment suit. Since each amount, taken separately, did not exceed the municipal court’s jurisdictional limit, the counterclaim was properly within its jurisdiction. Furthermore, the second and third causes of action were compulsory counterclaims arising from the main action, which should be set up regardless of amount. Therefore, the CFI, on appeal, had jurisdiction to act on the counterclaim.