INTERNATIONAL HARVESTER COMPANY OF THE PHILIPPINES, vs.

CRISANTO ARAGON,

Judge of Municipal Court of Manila, and YARAS and COMPANY, FAR EAST G.R. No. L-2372 | August 26, 1949

FACTS: International Harvester Company of the Philippines is the agent in the Philippines of the vessel S/S Belle of the Sea Which took on board
at Los Angeles, California, U. S. A., goods for shipment to Manila, and covered by Bill of Lading No. 105; When the S/S Belle of the Sea arrived in
Manila, the cargoes were discharged at the Government piers under the supervision and custody of Manila Terminal Co., Inc. Out of the goods
covered by Bill of Lading No. 105, one carton of assorted samples with a stipulated value of P200 was not delivered to Yaras and Company
which was lost through the negligence either of the Manila Terminal Co., Inc., or of the International Harvester Company of the Philippines. The
complaint prayed for judgment either against the defendant Manila Terminal Co., Inc., or the International Harvester Company of the
Philippines, agent of the vessel Belle of the Sea for the amount of P200, with legal interest from the date of the filing of the complaint. *Before
the trial in the Municipal Court of Manila could be proceeded with, the International Harvester of the Philippines filed a motion to dismiss, on
the ground that the Municipal Court of Manila had no jurisdiction to try case because the action involves admiralty or maritime jurisdiction,
which motion was overruled by the municipal court. *The Court of First Instance of Manila rendered judgment favor of the International
Harveter Company of the Philippines, ordering the judge of the municipal court to desist from taking cognizance of civil case against the
International Harvester Company of the Philippines.

ISSUE: WON the municipal court can take cognizance of civil case for recovery of the undelivered goods against the International Harvester
Company of the Philippines.

Held: in view of our conclusion that the cause of action of Yaras and Company against International Harvester Company of the Philippines
involves admiralty over which the courts of first instance have original jurisdiction and to which the jurisdiction of the justice of the peace
courts (including municipal courts) does not extend the respondent judge was properly restrained from further proceeding with civil case No.
IV-262. The liability of the International Harvester Company of the Philippines is predicated on the contract of carriage by sea between the
International Harvester Company of the Philippines and Yaras and Company as evidenced by Bill of Lading No. 105, independently of the
liability of the Manila Terminal Co., Inc, as operator of an arrastre service. Admiralty has jurisdiction over all maritime contracts, in whatever
form, wherever they were executed or are to be performed, but not over non-maritime contracts. Whether or not a contract is maritime does
not depend upon the English rule which conceded jurisdiction only to contracts made upon and the to be performed upon navigable water,
making the locality the test. It depends on the subject-matter of the contract, making the true criterion a maritime service or a maritime
transaction. Specifically, admiralty has jurisdiction of a proceeding

in remor in personamfor the breach of a contract of affreightment, whether evidenced by a bill of lading or a charter party. And typical of a
controversy over contracts of affreightment is a suit of one party against the other for loss of or damage to the cargo.

DIPOSITIVE: Wherefore, the judge of the municipal court is ordered to desist from taking cognizance of civil case against the International
Harvester Company of the Philippines.

Section 3. Section 33 of the same law is hereby amended to read as follows:

"Sec. 33. Jurisdiction of Metropolitan Trial Courts, Municipal Trial Courts and Municipal Circuit Trial Courts in Civil Cases. – Metropolitan Trial
Courts, Municipal Trial Courts, and Municipal Circuit Trial Courts shall exercise:

"(1) Exclusive original jurisdiction over civil actions and probate proceedings, testate and intestate, including the grant of provisional
remedies in proper cases, where the value of the personal property, estate, or amount of the demand does not exceed One hundred thousand
pesos (P100,000.00) or, in Metro Manila where such personal property, estate, or amount of the demand does not exceed Two hundred
thousand pesos (P200,000.00), exclusive of interest, damages of whatever kind, attorney's fees, litigation expenses, and costs, the amount of
which must be specifically alleged: Provided, That interest, damages of whatever kind, attorney's fees, litigation expenses, and costs shall be
included in the determination of the filing fees: Provided, further, That where there are several claims or causes of actions between the same or
different parties, embodied in the same complaint, the amount of the demand shall be the totality of the claims in all the causes of action,
irrespective of whether the causes of action arose out of the same or different transactions;

"(2) Exclusive original jurisdiction over cases of forcible entry and unlawful detainer: Provided, That when, in such cases, the defendant
raises the questions of ownership in his pleadings and the question of possession cannot be resolved without deciding the issue of ownership,
the issue of ownership shall be resolved only to determine the issue of possession; and
"(3) Exclusive original jurisdiction in all civil actions which involve title to, or possession of, real property, or any interest therein where
the assessed value of the property or interest therein does not exceed Twenty thousand pesos (P20,000.00) or, in civil actions in Metro Manila,
where such assessed value does not exceed Fifty thousand pesos (P50,000.00) exclusive of interest, damages of whatever kind, attorney's fees,
litigation expenses and costs: Provided, That in cases of land not declared for taxation purposes, the value of such property shall be determined
by the assessed value of the adjacent lots.