Perkins v. Roxas
REITERATIONFacts
The Antecedents: Respondent Eugene Arthur Perkins filed a complaint against Benguet Consolidated Mining Company (BCMC) for P71,379.90 in dividends declared on 52,874 shares registered in his name. BCMC's answer stated that payment was withheld due to demands on the shares by petitioner Idonah Slade Perkins and one George H. Engelhard, and prayed for interpleader. Procedural History: The trial court ordered Eugene Arthur Perkins to implead Idonah Slade Perkins and George H. Engelhard as defendants. The complaint was amended, and summons by publication was served on the non-resident defendants. Engelhard filed an answer. Petitioner Idonah Slade Perkins' objection to the court's jurisdiction was overruled by the trial court and this Court (G.R. No. 46831). Petitioner then filed an answer with a cross-complaint, asserting a New York judgment declaring her the sole owner of the shares and dividends. Eugene Arthur Perkins filed a reply and an answer, raising defenses against the enforcement of the New York judgment. Petitioner filed a demurrer to the reply, claiming the New York judgment was res judicata and the court lacked jurisdiction. The demurrer was overruled. The Petition: Petitioner Idonah Slade Perkins filed a petition for Certiorari, Prohibition, and Mandamus with the Supreme Court, alleging that the respondent judge was about to render judgment disregarding her constitutional rights and annulling the New York judgment, which she claimed was res judicata. She prayed for the annulment of the order overruling her demurrer and for a permanent prohibition against the respondent judge from taking further action except to dismiss the case.
Issue(s)
Whether the Court of First Instance of Manila has jurisdiction over the subject matter of civil case No. 53317, considering the alleged New York judgment claimed to be res judicata. Whether the respondent judge has the power to take cognizance of the case, despite the petitioner's assertion that the New York judgment is res judicata and that the local court lacks jurisdiction to annul, amend, reverse, or modify it.
Ruling
The petition is denied. The Court of First Instance of Manila has jurisdiction over the subject matter of the action, and the question of whether the New York judgment is res judicata or should be given efficacy goes to the merits of the case, not to the jurisdiction of the court.
Ratio Decidendi
On Issue 1: The Court held that the Court of First Instance of Manila has jurisdiction over the subject matter of civil case No. 53317. The amended complaint filed by Eugene Arthur Perkins sought the adjudication of title to certain shares of stock and the granting of affirmative reliefs, which fall within the general jurisdiction of the Court of First Instance. Furthermore, the Court of First Instance is empowered to adjudicate the demands in petitioner's cross-complaint, which sought to enforce a New York judgment and prayed for monetary awards and delivery of share certificates. This form of action, seeking to enforce a foreign judgment, is recognized and falls within the general jurisdiction of the Court of First Instance to adjudicate, settle, and determine. On Issue 2: The Court clarified that the fear expressed by the petitioner, that the respondent judge might render a judgment annulling the New York judgment, goes to the merits of the controversy and relates to the rights of the parties as between each other, not to the jurisdiction or power of the court. The test of jurisdiction is whether the tribunal has the power to enter upon the inquiry, not whether its conclusion in the course of it is right or wrong. If the decision is erroneous, it can be reversed on appeal, but the determination of the question itself is a rightful exercise of jurisdiction. Therefore, the respondent judge's potential ruling on the New York judgment does not divest the court of its jurisdiction over the case.
Main Doctrine
The Supreme Court held that the Court of First Instance of Manila possesses jurisdiction over the subject matter of the case, which involves the adjudication of title to shares of stock and the enforcement of a foreign judgment. The Court clarified that the question of whether a foreign judgment is res judicata or should be given efficacy in the Philippines goes to the merits of the case and not to the jurisdiction of the court. The test of jurisdiction is the power of the court to hear and decide a case, irrespective of whether its ultimate conclusion is correct or erroneous.