G.R. No. 123545 - People vs. Palijon

On May 10, 1999, private respondent Apolinario Serquina, Jr. initiated a civil action for damages before the Regional Trial Court (RTC), Branch 56, San Carlos City, alleging injuries arising from a vehicular accident.
The complaint detailed an incident occurring on January 21, 1999, between 9:00 and 10:00 a.m. in Pagal, San Carlos City, where a dump truck—owned by petitioner Norma Mangaliag and driven by her employee, petitioner Narciso Solano—allegedly sideswiped a tricycle occupied by Apolinario Serquina, Jr. and his co-passengers, after attempting to overtake.

Petitioners were accused of gross negligence, carelessness, and imprudence, leading to the injuries and permanent deformities sustained by private respondent.
The damages claimed included:

Actual damages covering medical expenses amounting to P71,392.00 and lost income of P25,000.00;
Moral damages of P500,000.00 for permanent facial deformity, physical suffering, and severe depression;
Attorney’s fees calculated on a contingent basis (25% of the total award).

On July 21, 1999, petitioners filed their answer with a counterclaim, denying liability and attributing negligence to the tricycle driver, Jayson Laforte, who was allegedly unlicensed.
After a pre-trial conference, the trial on the merits commenced, and petitioner Solano testified in defense after private respondent rested his case.

On March 8, 2000, petitioners, assisted by new counsel, filed a motion to dismiss the case on the ground of lack of jurisdiction, arguing that the case should fall within the Municipal Trial Court’s (MTC) jurisdiction due to the actual damages (P71,392.00) being below the threshold.
Petitioners supplemented their motion on March 24, 2000.

On April 17, 2000, RTC Judge Edelwina Catubig-Pastoral issued an order denying the motion to dismiss, basing her decision on the interpretation of Administrative Circular No. 09-94, Paragraph 2.
A subsequent motion for reconsideration filed by petitioners on May 19, 2000, was denied on June 13, 2000.

Petitioners sought certiorari before the Supreme Court, arguing that the jurisdiction of the RTC was improperly asserted since only actual damages (and not moral damages or other incidental claims) should determine jurisdiction.
By August 9, 2000, a temporary restraining order was issued by the Court, prompting the RTC Judge to desist temporarily from proceeding further in Civil Case No. SCC-2240.

The proper test for jurisdiction in an action for recovery of damages should consider solely the actual damages claimed (P71,392.00) and thereby fall under the jurisdiction of the MTC.
Moral, exemplary, nominal damages, and attorney’s fees should be viewed as incidental and only to be awarded upon a prior finding of negligence.
The objection on lack of jurisdiction ought to be entertained at any stage and cannot be waived simply by prior participation.

In cases of quasi-delict, the claim for moral damages is not incidental but a separate, independent cause of action, warranting its inclusion in determining jurisdiction.
The language of Administrative Circular No. 09-94 clearly directs that where the damage claim is the main cause of action, all damages (including moral damages) must be considered.
Petitioners’ participation in the trial should not estop the raising of a jurisdictional defect given the absence of laches since no final judgment had been rendered.

Whether the determination of the proper court’s jurisdiction in an action for recovery of damages should be based solely on the amount of actual damages claimed or whether the total claim—including moral, exemplary, nominal damages, and attorney’s fees—must be aggregated.

Whether petitioners are estopped from raising the issue of lack of jurisdiction due to their active participation in the trial, despite the fact that the jurisdictional defect was discovered only after proceedings had begun.

The proper interpretation and application of paragraph 2 of Administrative Circular No. 09-94 regarding the exclusion or inclusion of certain types of damages in computing the jurisdictional amount.

Whether the filing of a petition for certiorari to question the jurisdiction of the RTC is appropriate, given the established rules on judicial hierarchy and the proper stage for raising jurisdictional defects.