Roque v. San Miguel Brewery, Inc.
REITERATIONFacts
The Antecedents: Plaintiffs Lucas Roque, et al. filed a complaint seeking to recover P91,300.00 from San Miguel Brewery, Inc., Philippine Steam Navigation Co., and its agent, Philippine Everett Steamship Corporation. The claim arose from injuries sustained by Lucas Roque on October 17, 1956, aboard the "M/S KOLUMBUGAN" due to the alleged negligence of the defendants, specifically the explosion of an oxygen tank belonging to San Miguel Brewery, Inc., and the vessel's failure to sail for its destination. Procedural History: The Court of First Instance of Manila rendered a decision on February 26, 1959, ordering Philippine Steam Navigation Co. to pay P11,294.00 in damages, hospitalization, doctor's fees, lost income, and attorney's fees. The case was dismissed with respect to Everett Steamship Corporation. The cross-claim of Philippine Steam Navigation Co. against San Miguel Brewery, Inc., and the latter's counterclaim against the plaintiffs were also dismissed. Philippine Steam Navigation Co. and Lucas Roque appealed the decision to the Supreme Court. The Appeal: Appellant Philippine Steam Navigation Co. failed to file a brief. Appellant Lucas Roque's brief raised mainly questions of fact. The Supreme Court noted that these questions of fact, given the amount involved, were not within the exclusive appellate jurisdiction of the Court of Appeals.
Issue(s)
Whether the Supreme Court has exclusive appellate jurisdiction over the case, considering that the appeal raises questions of fact and the amount in controversy exceeds P50,000.00. Whether the case should be certified to the Court of Appeals.
Ruling
The Supreme Court resolved to certify the record of the appeal to the Court of Appeals for determination in accordance with law, pursuant to Section 31 of Republic Act No. 296, as amended.
Ratio Decidendi
On Issue 1: The Court found that appellant Lucas Roque's appeal raised mainly questions of fact. Under Sections 17 and 29 of Republic Act No. 296, as amended by Republic Act No. 2613, appeals involving questions of fact, where the amount in controversy exceeds P50,000.00, exclusive of interest and costs, fall within the exclusive appellate jurisdiction of the Court of Appeals. Therefore, the Supreme Court does not have exclusive appellate jurisdiction over such matters. The failure of appellant Philippine Steam Navigation Co. to file a brief further complicated the procedural posture of the appeal before the Supreme Court. On Issue 2: Pursuant to Section 31 of Republic Act No. 296, as amended, the Supreme Court has the authority to certify the record of an appeal to the Court of Appeals when it determines that the case falls within the latter's exclusive appellate jurisdiction. Given that the appeal raised questions of fact and the amount in controversy exceeded the threshold for the Court of Appeals' exclusive jurisdiction, the Court ordered the certification of the case to the Court of Appeals for proper determination.
Main Doctrine
The Supreme Court, in resolving an appeal where the appellant failed to file a brief and the issues raised primarily concern questions of fact, will certify the case to the Court of Appeals. This is in accordance with Republic Act No. 296, as amended, which vests exclusive appellate jurisdiction over such cases in the Court of Appeals when the amount in controversy exceeds P50,000.00, exclusive of interest and costs.