Cajilig v. Roberson
REITERATIONFacts
The Antecedents: Thirty-three (33) crew members of the M.S. "Alex" sued Flora Roberson Co., administratrix of the estate of Jovito Co, for the recovery of amounts allegedly deducted from their salaries for lodging furnished on board the vessel. The aggregate claim was P15,142.40, but individual claims did not exceed P534.00. Procedural History: The Court of First Instance of Iloilo rendered judgment in favor of the plaintiffs, ordering the defendant to reimburse the deductions with interests and attorney's fees, finding that the lodging was not "furnishing or housing" under the Minimum Wage Law. The defendant appealed to the Court of Appeals but subsequently moved to dismiss the case in the trial court, arguing lack of jurisdiction due to the small amount of individual claims. The trial court denied the motion, stating the case had already been decided. The defendant's record on appeal was approved and transmitted to the Supreme Court. The Petition: The defendant-appellant argued that the trial court lacked jurisdiction because the individual claims did not exceed P600, thus falling within the exclusive jurisdiction of the inferior court.
Issue(s)
Whether the Court of First Instance had jurisdiction over the case, considering the individual claims of the plaintiffs did not exceed P600. Whether a motion to dismiss based on lack of jurisdiction can be denied simply because the case has already been decided.
Ruling
The Supreme Court dismissed the complaint for lack of jurisdiction of the lower court over the subject-matter thereof. The Court held that the trial court did not acquire jurisdiction over the complaint.
Ratio Decidendi
On the issue of jurisdiction: The Court reiterated the settled rule that where several plaintiffs, with separate and distinct claims arising from the same transaction or series of transactions, jointly sue a common defendant, the jurisdiction of the court is determined by the amount of each separate claim, not the sum total of all claims. This rule is now incorporated in Section 88 of the Judiciary Act of 1948, as amended by Republic Act No. 2613, which clarifies that where claims are separately owned or due to different parties, each separate claim furnishes the jurisdictional test. In this case, each of the thirty-three plaintiffs had an independent cause of action for the recovery of illegally deducted wages. Therefore, the jurisdiction of the court should be determined by the amount of each individual claim, which did not exceed P600. Consequently, the Court of First Instance did not acquire jurisdiction over the complaint. On the timeliness of the motion to dismiss: The Court found the trial court's reason for denying the motion to dismiss – that the case had already been decided – to be plain error. It is axiomatic that jurisdiction is conferred by law and cannot be acquired by consent or by the parties' failure to object. An objection based on lack of jurisdiction may be raised at any stage of the proceedings, even for the first time on appeal. Since the lower court did not have jurisdiction, all proceedings and the judgment rendered therein were null and void. The delay in raising the objection by the defendant could not legalize the proceedings and the judgment.
Main Doctrine
Where several plaintiffs, having separate and distinct claims against a common defendant arising out of the same transaction or series of transactions and involving the same question of law or fact, jointly sue said defendant, it is the amount of each separate claim, and not the sum total of all the claims, that furnishes the test for determining the jurisdiction of the court.