Case Summary (G.R. No. 257446)
Factual Background
On May 10, 1999, Apolinario Serquina, Jr. filed a complaint for damages against Mangaliag and Solano, following a vehicular accident in San Carlos City, Pangasinan. The incident involved a dump truck owned by Mangaliag and driven by Solano sideswiping the tricycle that Serquina was occupying. The complaint outlined significant injuries, hospitalization costs amounting to P71,392.00, a claim for moral damages totaling P500,000.00, and loss of income of P25,000.00.
Motion to Dismiss and Court Orders
Petitioners filed an answer denying liability, attributing fault to the tricycle driver. Following the pre-trial and trial phases, petitioners submitted a motion to dismiss, contesting the jurisdiction of the Regional Trial Court (RTC), asserting that the Municipal Trial Court (MTC) had jurisdiction due to that the claimed principal amount of damages did not exceed P200,000.00. The RTC Judge, Edelwina Catubig-Pastoral, issued orders denying the motion to dismiss, citing Administrative Circular No. 09-94, which emphasizes that the total amount claimed, including moral and other damages, should be considered in assessing jurisdictional limits.
Jurisdictional Issues and Legal Arguments
Petitioners argue that only the amount of actual damages should determine jurisdiction, thus asserting that the RTC erred in not dismissing the case for lack of jurisdiction. They emphasized that moral damages claimed were ancillary and should not be considered in determining jurisdiction. In contrast, the private respondent contended that the claim for moral damages arises from a separate injury and must be included in the assessment of the court’s jurisdiction.
Estoppel and Court Hierarchy
The question of estoppel due to the petitioners’ active participation in the trial was raised, with respondent asserting that it precluded them from arguing lack of jurisdiction. However, jurisprudence states that objections to jurisdiction may be raised at any stage and that the court's lack of jurisdiction cannot be waived by active participation in proceedings. The doctrine of estoppel in such contexts is qualified and does not universally apply.
Legal Principles on Jurisdiction
Section 1 of Republic Act No. 7691 dictates exclusive jurisdiction for civil cases with claims exceeding P100,000.00, which was amended to P200,000.00 in relevant administrative circulars. The circular clarifies that when damages sought are the main cause of action, their inclusion is mandated for jurisdictional determination.
Interpretation of Damages
The Court concluded that Serquina’s claims for actual and moral damages should not be viewed separately, as the latter
...continue readingCase Syllabus (G.R. No. 257446)
Case Background
- This case is a petition for certiorari, filed by petitioners Norma Mangaliag and Narciso Solano, challenging the orders of the Regional Trial Court (RTC), Branch 56, San Carlos City.
- The petitioners sought to annul the Order dated April 17, 2000, which denied their motion to dismiss, and the Order dated June 13, 2000, which denied their motion for reconsideration.
- The underlying factual scenario involves a vehicular accident that occurred on January 21, 1999, resulting in injuries to private respondent Apolinario Serquina, Jr. and his companions.
Factual Allegations
- On the day of the accident, Serquina was a passenger in a tricycle driven by Jayson Laforte when a dump truck owned by Mangaliag and driven by Solano attempted to overtake another vehicle and collided with the tricycle.
- The incident resulted in serious injuries to Serquina and his companions, including a permanent facial deformity and severe depression, leading to medical expenses amounting to P71,392.00 and a claim for P500,000.00 in moral damages.
- The petitioners filed an answer denying liability, attributing negligence to the tricycle driver, Laforte, who allegedly operated the vehicle without a license.
Procedural History
- Following the pre-trial conference, the trial on the merits commenced, with private respondent resting his case before the petitioners presented their defense.
- On March 8, 2000, the petitioners filed a motion to dismiss, claiming lack of jurisdiction over the subject matter, arguing the case should fall under the jurisdiction of the Municipal Trial Court (MTC) because the principal amount claimed was P71,392.00.
- The RTC d