Case Digest (G.R. No. 212690)
Facts:
In Spouses Romeo Pajares and Ida T. Pajares vs. Remarkable Laundry and Dry Cleaning, petitioners Romeo and Ida Pajares, acting as a dealer outlet under a Remarkable Dealer Outlet Contract dated September 8, 2011, were obliged to deliver at least 200 kilos of laundry weekly to the main plant operated by respondent Remarkable Laundry and Dry Cleaning, represented by Archemedes G. Solis. On April 24, 2012, the Pajareses unilaterally ceased operations, prompting respondent to demand payment of penalties under Article IV of the contract. When petitioners failed to settle the amount, respondent filed on September 3, 2012 a “Breach of Contract and Damages” complaint before the Regional Trial Court (RTC), Branch 17, Cebu City, seeking Php 200,000.00 in incidental and consequential damages, Php 30,000.00 for legal expenses, Php 30,000.00 as exemplary damages, and Php 20,000.00 for costs. During pre-trial, the RTC dismissed the case on February 19, 2013 for lack of jurisdiction, holding t...Case Digest (G.R. No. 212690)
Facts:
- Parties and Complaint Filing
- Petitioners: Spouses Romeo and Ida Pajares.
- Respondent: Remarkable Laundry and Dry Cleaning, represented by Archemedes G. Solis.
- On September 3, 2012, respondent filed Civil Case No. CEB-39025 for “Breach of Contract and Damages” before RTC Cebu City, Branch 17.
- Contractual Undertaking and Alleged Breach
- Parties executed Remarkable Laundry Dealer Outlet Contract on September 8, 2011, obligating petitioners to deliver a minimum of 200 kilos of laundry items weekly.
- On April 30, 2012, petitioners ceased operations allegedly due to lack of personnel, violating Article IV (Standard Required Quota & Penalties) and Article XV (Breach Penalties) of the contract.
- Respondent demanded payment of penalties and damages under the contract’s liquidated-damages clause and Art. 1170, but petitioners did not pay.
- Procedural History
- RTC dismissed the complaint on February 19, 2013 for lack of jurisdiction, noting the total damage claim of ₱280,000 was below the ₱300,000 threshold for RTC.
- Respondent’s motion for reconsideration was denied on April 29, 2013.
- On December 11, 2013, the Court of Appeals (CA) reversed and set aside the RTC dismissal, ruling the action was for breach of contract (incapable of pecuniary estimation) and thus within RTC jurisdiction.
- Petitioners’ motion for reconsideration was denied by the CA, and they filed a Petition for Review on Certiorari with the Supreme Court, which was granted on June 29, 2015.
Issues:
- Nature of the Action
- Whether the complaint, albeit captioned “Breach of Contract and Damages,” is essentially an action for simple payment of damages.
- Whether, based on the relief sought, the subject matter is capable of pecuniary estimation.
- Jurisdictional Threshold
- Whether the RTC correctly dismissed the case for lack of jurisdiction under Section 19, BP 129, as amended, given the claimed damages totaled ₱280,000.
- Whether the CA erred in treating the action as non-pecuniary and thus within RTC exclusive original jurisdiction.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)