Case Digest (G.R. No. 102070)
Facts:
In Artemio Iniego v. The Honorable Judge Guillermo G. Purganan and Fokker C. Santos (G.R. No. 166876, March 24, 2006), petitioner Artemio Iniego, truck owner and employer of driver Jimmy T. Pinion, sought relief after private respondent Fokker C. Santos filed on March 1, 2002, a complaint for quasi-delict and damages stemming from a December 11, 1999 vehicular collision in Manila. Santos prayed for actual damages of ₱40,000, moral damages of ₱300,000, exemplary damages of ₱150,000, and attorney’s fees of ₱50,000. On August 24, 2002, Santos moved to declare Iniego in default; on August 28, 2002, Iniego filed a motion to admit his answer and dismiss the case for lack of jurisdiction. On October 21, 2002, RTC Branch 42, Manila, denied both motions in an Omnibus Order, ruling that a cause of action in quasi-delict is incapable of pecuniary estimation and thus within the exclusive jurisdiction of the RTC; on January 21, 2003, the RTC denied reconsideration. Iniego’s Rule 65 petitionCase Digest (G.R. No. 102070)
Facts:
- Parties and Cause of Action
- Petitioner Artemio Iniego (truck owner and employer) vs. private respondent Fokker C. Santos (jitney driver) arising from a vehicular collision on December 11, 1999, when the truck driven by Jimmy T. Pinion (Iniego’s employee) allegedly struck Santos’s jitney.
- Santos filed on March 1, 2002, a complaint for quasi-delict and damages against Pinion and Iniego before the Regional Trial Court (RTC), Branch 42, Manila, praying for:
- Actual damages – ₱40,000
- Moral damages – ₱300,000
- Exemplary damages – ₱150,000
- Attorney’s fees – ₱50,000
- Procedural History
- August 24, 2002 – Santos moved to declare Iniego in default for failure to file an answer.
- August 28, 2002 – Iniego filed a Motion to Admit and a Motion to Dismiss for lack of RTC jurisdiction, alleging the action was not capable of pecuniary estimation.
- October 21, 2002 – RTC issued an Omnibus Order denying both motions, ruling that the cause of action (quasi-delict) is not pecuniarily estimable and thus under RTC’s exclusive jurisdiction.
- January 21, 2003 – RTC denied Iniego’s Motion for Reconsideration, reaffirming that the “cause of action, not the amount prayed for,” is not capable of pecuniary estimation.
- Petition for certiorari under Rule 65 elevated the October 21, 2002 and January 21, 2003 orders to the Court of Appeals (CA).
- October 28, 2004 – CA denied due course to the petition and dismissed it for lack of merit.
- January 26, 2005 – CA denied reconsideration.
- March 24, 2006 – Petitioner filed the present petition for review on certiorari under Rule 45 before the Supreme Court.
Issues:
- Whether actions for damages based on quasi-delict are “capable of pecuniary estimation” such that jurisdiction depends on the amount claimed, placing actions with claims not exceeding ₱400,000 in municipal courts.
- Whether moral and exemplary damages should be excluded from the computation of the jurisdictional amount because they allegedly arise from a cause of action separate from the negligent act.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)