G.R. No. L-66620 - Flores vs. Mallare-Phillipps

Case Summary (G.R. No. L-66620)

Petitioner’s Allegations and Trial-Court Disposition

Petitioner alleged Binongcal owed P11,643.00 for tires bought on credit (August–October 1981) and Calion owed P10,212.00 for tires bought on credit (March 1981–January 1982). Respondent Binongcal moved to dismiss for lack of jurisdiction because each claim was below the P20,000 jurisdictional threshold for the Regional Trial Court under Section 19(8) of Batas Pambansa Blg. 129 (BP 129). Calion joined the motion. The trial court dismissed the complaint for lack of jurisdiction, finding misjoinder and that neither claim individually met the jurisdictional amount.

Procedural Points on the Appeal

Petitioner sought relief by certiorari to this Court but did not attach a copy of the complaint, mistakenly believing the second paragraph of Section 39 of BP 129 required transmission of the entire original record. The Court clarified that ordinary appeals to the Court of Appeals are governed by Section 20 of the Interim Rules (second paragraph of Section 39 of BP 129), whereas petitions for review on certiorari to this Court are governed by Rule 45 of the Rules of Court (Section 25 of the Interim Rules).

Key Dates

Relevant transaction periods: Binongcal (August–October 1981), Calion (March 1981–January 1982). Motion to dismiss filed: December 15, 1983. Decision under review issued by this Court on September 24, 1986.

Applicable Law and Doctrinal Provisions

Primary statutory provisions discussed: Section 33(1) of BP 129 (totality rule), Section 11 of the Interim Rules (application of the totality rule), and Section 19(8) of BP 129 (jurisdictional amount for the RTC). Procedural joinder rules invoked: Section 6 of Rule 3 (permissive joinder of parties) and Section 5 of Rule 2 of the Rules of Court. Comparison is made to the former Section 88 of the Judiciary Act of 1948 (former totality proviso). The constitutional framework in force at the time of decision was the 1973 Constitution.

Issue Presented

Whether the “totality rule” as expressed in Section 33(1) of BP 129 and Section 11 of the Interim Rules permits aggregation of separate claims against different parties in a single complaint so as to confer jurisdiction on the Regional Trial Court, notwithstanding the permissive-joinder limitations of Rule 3, Section 6.

Legal Background: Totality Rule and Permissive Joinder

The totality rule in the present law provides that where there are several claims or causes of action embodied in the same complaint, the jurisdictional test may be the aggregate of all money demands, irrespective of whether the causes of action arose out of the same or different transactions. The Rules of Court, however, continue to govern permissive joinder: under Section 6 of Rule 3, persons may join as plaintiffs or be joined as defendants where rights of relief arise out of the same transaction or series of transactions and where a common question of law or fact exists. The former rule (Judiciary Act, Section 88) contained an express proviso that separated claims “owned by or due to different parties” would require each separate claim to furnish the jurisdictional test; that proviso is absent in BP 129.

Court’s Comparative Analysis of Former and Present Rules

The Court explained that where a single plaintiff sues a single defendant on multiple separate causes of action, there is no change between the former and present rules: the total of the claims is the jurisdictional measure. The distinction arises in cases of permissive joinder of parties (multiple plaintiffs or multiple defendants). Under the former rule, separate claims owned by different parties required each claim to be measured separately for jurisdictional purposes. Under BP 129 and the Interim Rules, the totality rule now applies to joined claims as well, but only where the joinder itself is proper under Rule 3, Section 6 — i.e., the causes of action must arise out of the same transaction or series of transactions and involve common questions of law or fact.

Application of Precedents and Illustrative Cases

The Court reviewed earlier cases (e.g., Vda. de Rosario; Soriano y Cia v. Jose; International Colleges, Inc. v. Argonza; Brillo v. Buklatan; Gacula v. Martinez) that interpret

Case Syllabus (G.R. No. L-66620)

Case Citation and Panel

228 Phil. 360, Second Division, G.R. No. 66620, September 24, 1986.
Decision authored by Justice Feria.
Justices Fernan, Alampay, Gutierrez, Jr., and Paras concurred.

Parties and Posture

Petitioner: Remegio (styled in the source as REMEGIO V. FLORES, PETITIONER).
Respondents: Hon. Judge Heilia S. Mallare-Phillipps, Ignacio Binongcal, and Fernando Calion.
Nature of appeal: Petition for review on certiorari to the Supreme Court from an order of the Regional Trial Court (RTC) of Baguio City and Benguet Province dismissing petitioner’s complaint for lack of jurisdiction.

Relevant Procedural History

Petitioner appealed by certiorari from the RTC order dismissing his complaint for lack of jurisdiction.
Petitioner did not attach a copy of his complaint to his petition to the Supreme Court, under the mistaken belief that the entire original record would be transmitted pursuant to the second paragraph of Section 39 of Batas Pambansa Blg. 129 (BP 129).
The Court clarified that the second paragraph of Section 39 of BP 129 applies only to ordinary appeals from the RTC to the Court of Appeals (per Section 20 of the Interim Rules); appeals to the Supreme Court by petition for review on certiorari are governed by Rule 45 of the Rules of Court (per Section 25 of the Interim Rules).

Relevant Factual Allegations (as stated in the RTC order)

First cause of action: Allegation against respondent Ignacio Binongcal for refusing to pay P11,643.00 representing the cost of truck tires purchased on credit from petitioner on various occasions from August to October, 1981.
Second cause of action: Allegation against respondent Fernando Calion for refusing to pay P10,212.00 representing the cost of truck tires purchased on credit from petitioner on several occasions from March, 1981 to January, 1982.

Motions and Lower Court Proceedings

On December 15, 1983, counsel for respondent Binongcal filed a Motion to Dismiss on the ground of lack of jurisdiction, asserting:
- The amount demanded against Binongcal was only P11,643.00, and under Section 19(8) of BP 129 the RTC has exclusive original jurisdiction only if the amount demanded is more than P20,000.00.
- Although there was another alleged indebtedness by Calion of P10,212.00, his obligation was separate and distinct.
At the hearing on the Motion to Dismiss, counsel for Calion joined in the motion on the ground of lack of jurisdiction.
Counsel for petitioner opposed the Motion to Dismiss.
The trial court dismissed the complaint for lack of jurisdiction.

Legal Issues Presented

Whether the totality rule under Section 33(1) of BP 129 and Section 11 of the Interim Rules permits aggregation of separate claims against different defendants or separate claims by different plaintiffs so as to confer jurisdiction on the RTC in the circumstances presented.
Whether the RTC correctly dismissed the complaint for lack of jurisdiction given the nature of the claims and the joinder of parties.

Statutory Provisions Quoted in the Decision

Section 33(1) of BP 129 (pertinent portion quoted):
- "Provided, That where there are several claims or causes of action 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..."
Section 11 of the Interim Rules (quoted):
- "Application of the totality rule. - In actions where the jurisdiction of the court is dependent on the amount involved, the test of jurisdiction shall be the aggregate sum of all the money demands, exclusive only of interest and costs, irrespective of whether or not the separate claims are owned by or due to different parties. If any demand is for damages in a civil action, the amount thereof must be specifically alleged."
Former rule under Section 88 of the Judiciary Act of 1948 as amended (quoted portion):
- "...Where there are several claims or causes of action between the same parties embodied in the same complaint, the amount of the demand shall be the totality of the demand in all the causes of action, irrespective of whether the causes of action arose out of the same or different transactions; but where the claims or causes of action joined in a single complaint are separately owned by or due to different parties, each separate claim shall furnish the jurisdictional test..."

Petitioner’s Argument

Petitioner