Sante
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SANTE V CLARAV ALL In April 5, 2004, Kalashian, the private respondent filed o!plaint a"ainst the Sante spo#ses $hen %rs& Sante #ttered !aliio#s and de!eanin" $ords a"ainst her and her friend& She also avers that the Sante spo#ses $ent aro#nd Natividad, 'an"asinan tellin" people that she is protetin" and #ddlin" the s#spets in the (illin" of their relative Th#s, respondent pra)ed that petitioners *e held lia*le to pa) !oral da!a"es in the a!o#nt of '+00,000&00 '50,000&00 as e-e!plar) da!a"es '50,000&00 attorne)s fees '20,000&00 liti"ation e-penses and osts of s#it& Sante Spo#ses filed %T. on the "ro#nd that it $as the %#niipal Trial Co#rt in Cities /%TCC and not the RTC of 1a"#io, that had #risdition over the ase& The) ar"#ed that the a!o#nt of the lai! for !oral da!a"es $as not !ore than the #risditiona l a!o#nt of '+00,000&00, *ea#se the lai! for e-e!plar) da!a"es sho#ld *e e-l#ded in o!p#tin" the total lai!& The TC denied the !otion and held that the total lai! of respondent a!o#nted to ' 420,000&00 $hih $as a*ove the #risditional a!o#nt for %TCCs o#tside %etro %anila& 'etitioners filed a 'etition for Certiorari and 'rohi*ition $ith the CA on 3#l) 4, 2004, re spondent and her h#s*and fi le d an A!ended Co !pla int [11] in rea sin" the la i! for !or al da!a"e s fro! '+00,000&00 to ',000,000&00& Sante Spo#ses filed %T. *#t $as denied a"ain petitioners a" ain filed a 'etition for Certiorari and 'rohi*ition 3AN 2+,2006 The CA "ranted the petitioner7s / ST %oti on an d hel d tha t the ase lea rl) falls #nder th e #risdi tion of the %TC C as the alle"ations sho$ that plaintiff $as see(in" to reover !oral da!a"es in the a!o#nt of '+00,000&00, $hih a!o#nt $as $ell $ithin the #r isdi ti onal a!o#nt of the %TCC& T he Co# rt of Ap pea ls adde d that the tot alit ) of la i! r#l e #sed for det er!inin " $hi h o#r t had #r isdi ti on o# ld not * e app lie d to the i nsta nt a se *e a#s e pla inti ff s lai ! for e -e!p lar) da!a "es $as no t a sepa rate and di sti nt a#se o f ation fro! her lai! of !oral da!a"es, *#t !erel) inidental to it& Th#s, the pra)er for e-e!plar) da!a"es sho#ld *e e-l#ded in o!p#tin" the total a!o#nt of the lai!& 3AN8AR9 +,200 : The CA denied the petitioner7s /2 N. %otion o#rt held that the total or a""re"ate a!o#nt de!anded in the o!plaint onstit#tes the *asis of #risdition& The Co#rt of Appeals additionall) r#led that respondent an a!end her o!plaint *) inreasin" the a!o#nt of !oral da!a"es fro! '+00,000&00 to ',000,000&00, on the "ro#nd that the trial o#rt has #risdition over the ori"inal o!plaint and respondent is entitled to a!end her o!plaint as a !atter of ri"ht #nder the R#les& ;ene, this petition& ISS8E< .id the RT C a=#ire #risdition over the ase> and 2 .id the RT C o!!it "rave a*#se of disretion in allo$in" the a!end!ent of the o!plaint> SC R8LIN?< @e de n) the petition, $hih altho#"h deno!inated as a petition for ertiorari, $e treat as a petition for revie$ on ertiorari #nder R#le 45 in vie$ of the iss#es raised& SEC& & Jurisdiction in civil cases& Re"ional Trial Co#rts shall e-erise e-l#sive ori"inal #risdition< - - - - /B In all other ases in $hih the de!and, e-l#sive of interest, da!a"es of $hatever (ind, attorne)s fees, liti"ation e-penses, and osts or the val#e of the propert) in ontrovers) e-eeds ne h#ndred tho#sand pesos /'00,000&00 or, in s#h other ases in %etro %anila, $here the de!and, e-l#sive of the a*ove!entioned ite!s e-eeds T$o h#ndred tho#sand pesos /'200,000&00& Setion 5 of Rep& At No& D f#rther provides< SEC& 5& After five /5 )ears fro! the effetivit) of this At, the #risditional a!o#nts !entioned in Se& /+, /4, and /B and Se& ++/ of 1atas 'a!*ansa 1l"& 2 as a!ended *) this At, shall *e ad#sted to T$o h#ndred tho#sand pesos /'200,000&00& ive /5 )ears thereafter, s#h #risditional a!o#nts shall *e ad#sted f#rther to Thre e h#ndr ed tho#s and pesos /'+00 ,000& 00< Provided, however , That in the a se of %e tr o%anil a, the a*ove!entioned #risditional a!o#nts shall *e ad#sted after five /5 )ears fro! the effetivit) of this At to o#r h#ndred tho#sand pesos /' 400,000&00& 1) virt#e of the SC ir#lar iss#ed p#rs#ant to RA D< %arh 20, : 200( e* 22,2046 +00( In this re"ard, Ad!inis trative Cir#lar No& 064 [19] is instr#tive< - - - - 2& The e-l#sion of the ter! da!a"e s of $hatever (ind in deter!inin" the #risdi tional a!o#nt #nder Setion /B and Setion ++ / of 1&'& 1l"& 2, as a!ended *) R&A& No& D, applies to ases $here the da!a"es are !erel) inidental to or a onse=#ene of the !ain a#se of ation& However, in cases where the claim for damages is the main cause of action, or one of the causes of action, the amount of such claim shall be considered in determining the jurisdiction of the court. /E!phasis o#rs& It is settled that #risdition is onferred *) la$ *ased on the fats alle"ed in the o!plaint sine the latter o!prises a onise state!ent of
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Sante
Transcript of Sante
SANTE V CLARAVALLIn April 5, 2004, Kalashian, the private respondent filed complaint against the Sante spouses when Mrs. Sante uttered malicious and demeaning words against her and her friend. She also avers that the Sante spouses went around Natividad, Pangasinan telling people that she is protecting and cuddling the suspects in the killing of their relative
Thus, respondent prayed that petitioners be held liable to pay moral damages in the amount ofP300,000.00;P50,000.00 as exemplary damages;P50,000.00 attorneys fees;P20,000.00 litigation expenses; and costs of suit.Sante Spouses filed MTD on the ground that it was the Municipal Trial Court in Cities (MTCC) and not the RTC of Baguio, that had jurisdiction over the case.They argued that the amount of the claim for moral damages was not more than the jurisdictional amount ofP300,000.00, because the claim for exemplary damages should be excluded in computing the total claim.
The TC denied the motion and held that the total claim of respondent amounted toP420,000.00 which was above the jurisdictional amount for MTCCs outside Metro Manila.
Petitioners filed a Petition for Certiorari and Prohibition with the CAon July 14, 2004, respondent and her husband filed an Amended Complaint[11]increasing the claim for moral damages fromP300,000.00 toP1,000,000.00.
Sante Spouses filed MTD but was denied again
petitioners again filed a Petition for Certiorari and Prohibition
JAN 23,2006- The CA granted the petitioners (1ST) Motion and held that the case clearly falls under the jurisdiction of the MTCC as the allegations show that plaintiff was seeking to recover moral damages in the amount ofP300,000.00, which amount was well within the jurisdictional amount of the MTCC.The Court of Appeals added that the totality of claim rule used for determining which court had jurisdiction could not be applied to the instant case because plaintiffs claim for exemplary damages was not a separate and distinct cause of action from her claim of moral damages, but merely incidental to it.Thus, the prayer for exemplary damages should be excluded in computing the total amount of the claim.
JANUARY 31,2006 The CA denied the petitioners (2ND) Motion court held that the total or aggregate amount demanded in the complaint constitutes the basis of jurisdiction.The Court of Appeals additionally ruled that respondent can amend her complaint by increasing the amount of moral damages fromP300,000.00 toP1,000,000.00, on the ground that the trial court has jurisdiction over the original complaint and respondent is entitled to amend her complaint as a matter of right under the Rules.
Hence, this petition.
ISSUE:1)Did the RTC acquire jurisdiction over the case? and2)Did the RTC commit grave abuse of discretion in allowing the amendment of the complaint?
SC RULING:We deny the petition, which although denominated as a petition for certiorari, we treat as a petition for review on certiorari underRule 45in view of the issues raised.
SEC. 19.Jurisdiction in civil cases. Regional Trial Courts shall exercise exclusive original jurisdiction:x x x x(8) In all other cases in which the demand, exclusive of interest, damages of whatever kind, attorneys fees, litigation expenses, and costs or the value of the property in controversy exceeds One hundred thousand pesos (P100,000.00) or, in such other cases in Metro Manila, where the demand, exclusive of the abovementioned items exceeds Two hundred thousand pesos (P200,000.00).
Section 5 of Rep. Act No. 7691 further provides:SEC. 5. After five (5) years from the effectivity of this Act, the jurisdictional amounts mentioned in Sec. 19(3), (4), and (8); and Sec. 33(1) of Batas Pambansa Blg. 129 as amended by this Act, shall be adjusted to Two hundred thousand pesos (P200,000.00). Five (5) years thereafter, such jurisdictionalamounts shall be adjusted further to Three hundred thousand pesos (P300,000.00):Provided, however, That in the case of MetroManila, the abovementioned jurisdictional amounts shall be adjusted after five (5) years from the effectivity of this Act to Four hundred thousand pesos (P400,000.00).
By virtue of the SC circular issued pursuant to RA 7691:March 20,1999 200kFeb 22,20114- 300k
In this regard, Administrative Circular No. 09-94[19]is instructive:x x x x2. The exclusion of the term damages of whatever kind in determining the jurisdictional amount under Section 19 (8) and Section 33 (1) of B.P. Blg. 129, as amended by R.A. No. 7691, applies to cases where the damages are merely incidental to or a consequence of the main cause of action.However, in cases where the claim for damages is the main cause of action, or one of the causes of action, the amount of such claim shall be considered in determining the jurisdiction of the court.(Emphasis ours.)It is settled that jurisdiction is conferred by law based on the facts alleged in the complaintsince the latter comprises a concise statement of the ultimate facts constituting the plaintiffs causes of action.
