Case Summary (G.R. No. 136109)
Procedural History
The case originates from a complaint filed by Manuel Dulawon against RCPI for breach of contract of lease with damages. The complaint was lodged with the Regional Trial Court of Tabuk, Kalinga, on June 18, 1997. RCPI moved to dismiss the complaint, arguing a lack of jurisdiction because the amount claimed (P84,000.00) did not exceed the jurisdictional threshold of P100,000.00 for Regional Trial Courts. The trial court denied this motion, which led RCPI to seek relief from the Court of Appeals. The appellate court dismissed RCPI’s petition on April 30, 1998, and subsequently denied the motion for reconsideration on October 15, 1998.
Jurisdictional Issue
The central issue is whether the Regional Trial Court has jurisdiction over the breach of contract complaint. The relevant provision under Batas Pambansa Blg. 129 states that Regional Trial Courts have exclusive original jurisdiction over civil actions where the demand exceeds P100,000.00, excluding interest and costs. However, claims for damages incidental to the principal action are not included in determining jurisdiction unless the claim of damages constitutes the main cause of action.
Nature of the Complaint
Dulawon’s complaint clearly outlines a cause of action for breach of contract, citing specific details of the lease agreement, its terms, and the failure of RCPI to pay rental fees, which collectively suggest that the essence of Dulawon’s allegations focused on the enforcement of the lease agreement. The Court highlighted that the primary remedy sought is thus the specific performance of the lease contract.
Legal Principles on Jurisdiction
The decision referenced the distinction between actions primarily aimed at recovering sums of money versus those seeking specific performance, which are considered not capable of pecuniary estimation. In cases where the enforcement of a contract is the primary relief sought, any monetary claims are deemed incidental. This is aligned with jurisprudence indicating that the nature of the action determines jurisdiction irrespective of the claimed monetary value or other damages.
Court's Reasoning
The Court concluded that the complaint primarily sought specific performance of the lease agreement and that monetary claims for unpaid rentals only stemmed from this primary pursuit. As such, th
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Case Overview
- This case involves a petition for review filed by Radio Communications of the Philippines, Inc. (RCPI) against the decision of the Court of Appeals regarding a breach of contract of lease complaint initiated by private respondent Manuel Dulawon.
- The Court of Appeals dismissed the petition for certiorari filed by RCPI, leading to further legal proceedings.
Background of the Case
- On June 18, 1997, Manuel Dulawon filed a complaint for breach of contract of lease with damages against RCPI in the Regional Trial Court of Tabuk, Kalinga, Branch 25.
- RCPI contested the court's jurisdiction, arguing that the Municipal Trial Court should handle the case since the amount in controversy, P84,000.00, was below the jurisdictional limit of P100,000.00 for Regional Trial Courts.
- The Regional Trial Court denied RCPI's motion to dismiss, leading RCPI to seek a certiorari petition from the Court of Appeals.
Court of Appeals Decision
- On April 30, 1998, the Court of Appeals dismissed RCPI's petition for lack of merit, stating that the case should remain within the Regional Trial Court.
- The motion for reconsideration filed by RCPI was subsequently denied on October 15, 1998.
Jurisdictional Issue
- The central issue for resolution was whether the Regional Trial Court had jurisdiction over the complaint filed b