Case Summary (G.R. No. 140746)
Petitioners
Pantranco North Express, Inc. and its driver, Alexander Buncan. They denied the allegations, contested the jurisdiction of the Regional Trial Court (arguing the proper forum was the Metropolitan/Municipal Trial Court), disputed liability, and later raised denial of due process.
Respondents
Standard Insurance Company, Inc. (insurer that paid P8,000.00) and Martina Gicale (owner of the jeepney who paid P13,415.00 and sought reimbursement).
Key Dates and Procedural Posture
Accident: October 28, 1984. Trial court Decision in favor of respondents: June 5, 1992 (awarding P8,000.00 to Standard with interest; P13,415.00 to Martina with interest; P10,000.00 attorney’s fees; litigation expenses and costs). Court of Appeals affirmed: July 23, 1999. Motion for reconsideration denied: November 4, 1999. Supreme Court denied the petition for review on certiorari and affirmed the Court of Appeals decision (decision rendered in 2005).
Applicable Law and Rules (including Constitutional Basis)
- Applicable Constitution: 1987 Philippine Constitution (decision rendered after 1990).
- Civil Code: Article 2176 (quasi-delict) — basis for liability for tort/negligence.
- Rules of Court: Sec. 6, Rule 3 (permissive joinder of parties); Sec. 5(d), Rule 2 (joinder of causes of action — aggregate amount as test of jurisdiction).
- Batas Pambansa Blg. 129 (Judiciary Reorganization Act of 1980): Sec. 33(1) (totality rule regarding aggregation of claims); Sec. 19 (RTC exclusive original jurisdiction where demand exceeds P20,000.00 at the relevant time).
- Noted jurisprudence and doctrinal points cited in the record (e.g., Mendoza; Mirasol; Zacarias) concerning identity of cause of action, finality of factual findings, and the essence of due process.
Trial Court Ruling
The Regional Trial Court rendered judgment for the plaintiffs (Standard Insurance Company and Martina Gicale), ordering defendants Pantranco and Alexander Buncan to pay P8,000.00 (to Standard) with interest from November 27, 1984; P13,415.00 (to Martina) with interest from October 22, 1984; attorney’s fees of P10,000.00; and litigation expenses and costs.
Court of Appeals Ruling — Overview of Reasoning
The Court of Appeals affirmed the trial court. Its central holdings: (1) permissive joinder of respondents’ claims was proper because both claims arose out of the same vehicular accident and involved the common question of petitioners’ negligence; (2) under the totality rule, the individual monetary claims (P8,000.00 and P13,415.00) aggregate to P21,415.00, exceeding the P20,000.00 threshold applicable at the time, thereby conferring RTC jurisdiction; (3) any asserted misjoinder did not affect subject-matter jurisdiction and was not ground for dismissal; (4) petitioners had waived presentation of their evidence by repeatedly failing to appear after notice, so the case was properly deemed submitted; (5) evidence preponderantly established petitioners’ liability for quasi-delict under Article 2176.
Issues on Review Presented by Petitioners
I. Whether the trial court had jurisdiction given petitioners’ contention that respondents’ causes of action did not arise from the same transaction nor raise common questions of law or fact.
II. Whether petitioners are liable to respondents based on the evidence and applicable law.
III. Whether petitioners were deprived of due process.
Analysis — Jurisdiction: Permissive Joinder and the Totality Rule
- Permissive joinder (Sec. 6, Rule 3) requires: (a) the right to relief arises out of the same transaction or series of transactions; (b) a question of law or fact common to all plaintiffs or defendants; and (c) joinder not otherwise proscribed by rules on jurisdiction and venue. The court found a single transaction (the collision) and a common factual question (negligence of petitioners), so the joinder elements were satisfied.
- Joinder of causes of action test for monetary claims (Sec. 5(d), Rule 2) makes the aggregate amount the test of jurisdiction. The BP 129 totality rule (Sec. 33(1)) reinforces that where several claims or causes of action are embodied in the same complaint, the amount demanded is the total of those claims. Here Standard’s P8,000.00 and Martina’s P13,415.00 aggregate to P21,415.00, exceeding the P20,000.00 jurisdictional threshold for the RTC at the time.
- The Court of Appeals correctly concluded that the RTC had exclusive original jurisdiction under Sec. 19, B.P. Blg. 129. The court also noted that subsequent statutory changes (R.A. 7691 expanding lower court jurisdiction effective April 15, 1994) were not operative at the time the complaint was filed.
Analysis — Liability (Quasi-delict) and Standard of Review
- The trial court and Court of Appeals found petitioners negligent and liable under Article 2176 (quasi-delict). The Supreme Court emphasized the well-settled rule that factual findings of the trial court, when affirmed by the Court of Appeals, are binding and conclusiv
Case Syllabus (G.R. No. 140746)
Procedural Posture
- Petition for review on certiorari brought before the Supreme Court assailing the Court of Appeals Decision dated July 23, 1999 and Resolution dated November 4, 1999 in CA-G.R. CV No. 38453.
- Trial court: Regional Trial Court (RTC), Branch 94, Manila — rendered Decision on June 5, 1992 in favor of respondents Standard Insurance Company and Martina Gicale.
- Court of Appeals: Affirmed the trial court’s judgment by Decision dated July 23, 1999; denied petitioners’ motion for reconsideration by Resolution dated November 4, 1999.
- Supreme Court: Petition for review on certiorari filed by petitioners Pantranco North Express, Inc. and driver Alexander Buncan; Supreme Court denied the petition and affirmed the Court of Appeals’ Decision and Resolution; costs against petitioners; decision penned by Justice Sandoval-Gutierrez; concurrence by Justices Panganiban (Chairman), Corona, Carpio-Morales, and Garcia.
Relevant Dates and Parties
- Date of accident: October 28, 1984 (afternoon; raining).
- Owner of jeepney and respondent claimant: Martina Gicale.
- Driver of jeepney at time of accident: Crispin Gicale (son of Martina Gicale).
- Petitioner carrier and owner of bus: Pantranco North Express, Inc.
- Petitioner driver of bus: Alexander Buncan.
- Insurer of the jeepney and respondent: Standard Insurance Company, Inc.
- Trial court decision date: June 5, 1992.
- Court of Appeals decision date: July 23, 1999; MR denied November 4, 1999.
- Supreme Court decision date: March 16, 2005 (G.R. No. 140746).
Facts
- Crispin Gicale was driving a passenger jeepney owned by his mother, Martina Gicale, on October 28, 1984.
- It was raining and both vehicles were traveling northbound along the National Highway in Talavera, Nueva Ecija.
- A passenger bus owned by Pantranco North Express and driven by Alexander Buncan was trailing behind the jeepney and, while negotiating a curve, overtook the jeepney.
- In the course of overtaking, the bus struck the left rear side of the jeepney and then sped away.
- The incident was reported to the Talavera Police Station and to Standard Insurance Company, the jeepney’s insurer.
- Total cost of repair to the jeepney amounted to P21,415.00.
- Standard Insurance paid P8,000.00; Martina Gicale paid the remaining P13,415.00.
- Standard and Martina demanded reimbursement from Pantranco and its driver; petitioners refused, prompting respondents to file a complaint for sum of money in the RTC.
Trial Court Judgment (June 5, 1992)
- Judgment in favor of plaintiffs Standard Insurance Company and Martina Gicale, and against defendants Pantranco Bus Company and Alexander Buncan, ordering:
- Payment to Standard Insurance: P8,000.00 with interest from November 27, 1984 until fully paid.
- Payment to Martina Gicale: P13,415.00 with interest from October 22, 1984 until fully paid.
- Payment of attorney’s fees: P10,000.00.
- Payment of expenses of litigation and costs of suit.
Court of Appeals Ruling (July 23, 1999)
- Affirmed the RTC decision.
- Rejected appellants’ argument that individual claims fell under municipal trial court jurisdiction, applying the Totality Rule under Section 19, Batas Pambansa Blg. 129 to aggregate the claims.
- Held total claims amounted to P21,415.00, exceeding the P20,000.00 jurisdictional threshold for the RTC at the relevant time.
- Addressed alleged misjoinder of parties: even assuming misjoinder, it does not affect jurisdiction nor warrant dismissal under Rule 7, Section 11.
- Found a common question of fact: whose fault or negligence caused the damage to the jeepney.
- Rejected appellants’ assertion they were denied their day in court: explained that the case was deemed submitted for decision because defendants waived presentation of evidence by failing to appear at scheduled hearings despite notice; trial court did not declare defendants in default because default requires failure to file an answer.
- Concluded evidence preponderantly established petitioners’ liability for quasi-delict under Article 2176 of the Civil Code.
- Petitioners’ motion for reconsideration to the CA denied by resolution dated November 4, 1999.
Issues Raised by Petitioners (as framed in petition)
- Whether the trial court had jurisdiction over the subject action considering respondents’ respective causes of action did not arise out of the same transaction nor involved common questions of law and fact.
- Whether p