Case Summary (G.R. No. 173915)
Factual Background
Respondent, Vita Kalashian, filed a complaint for damages against petitioners Irene and Reynaldo Sante before the RTC of Baguio City. The complaint arose from alleged defamatory and malicious statements by petitioner Irene Sante at a police station in Natividad, Pangasinan, in the presence of others. Respondent claimed moral damages of ₱300,000.00, exemplary damages of ₱50,000.00, attorney’s fees of ₱50,000.00, litigation expenses of ₱20,000.00, and costs of suit. Petitioners moved to dismiss the complaint, arguing that it fell within the jurisdiction of the Municipal Trial Court in Cities (MTCC) since the claim for moral damages alone did not exceed the MTCC’s jurisdictional amount.
Jurisdictional Dispute on Amount Claimed
The RTC denied the motion to dismiss, holding that the total claim amounted to ₱420,000.00, surpassing the MTCC’s jurisdictional threshold, and thus the RTC had jurisdiction. Petitioners filed an original petition for certiorari with the Court of Appeals (Seventh Division) challenging this. Meanwhile, respondent filed an amended complaint increasing the moral damages to ₱1,000,000.00. The trial court allowed the amendment and denied petitioners’ motions to dismiss again.
Court of Appeals Decisions
The Court of Appeals Seventh Division ruled that the total claim should exclude exemplary damages from the jurisdictional computation because such damages were incidental to the moral damages claim. With moral damages claimed at ₱300,000.00, the Court found jurisdiction proper in the MTCC and dismissed the complaint for lack of jurisdiction. However, in a separate petition (CA-G.R. SP No. 87563), the Court, this time the Seventeenth Division, affirmed the RTC’s ruling that the entire amount claimed, including exemplary damages and attorney’s fees, forms the basis for jurisdiction. The Court also ruled that the amendment increasing moral damages to ₱1,000,000.00 was allowable.
Issues Raised for Supreme Court Review
- Whether the RTC had jurisdiction over the case despite petitioners’ claims that it was within the exclusive jurisdiction of the MTCC given the amount claimed.
- Whether the RTC abused discretion in permitting the amendment of the complaint to increase moral damages, which petitioners argued was done merely to confer jurisdiction.
Applicable Legal Provisions on Jurisdiction
Section 19(8) of Batas Pambansa Blg. 129, as amended by Republic Act No. 7691, confers exclusive original jurisdiction to the RTC in all cases where "[t]he demand ... exceeds One hundred thousand pesos (₱100,000)," adjusted later to ₱300,000 for courts outside Metro Manila by 2004. Jurisdictional computations exclude interest but include all damages, attorney’s fees, litigation expenses, and costs.
Jurisdictional Amount Adjustments and Supreme Court Guidelines
Supreme Court Circulars and Office of the Court Administrator Circulars increased the MTCC jurisdictional amount to ₱300,000 effective February 22, 2004. Administrative Circular No. 09-94 clarifies the rules on inclusion or exclusion of damages in jurisdictional computations: damages that are incidental to the main cause of action are excluded, but where the claim for damages is the main cause of action or one of the causes, all damages claimed must be included.
Supreme Court’s Analysis on Jurisdiction
The Court held that since the principal cause of action was for the recovery of damages, all claims for damages—including moral, exemplary, attorney’s fees, and litigation expenses—must be aggregated to determine jurisdiction. The complaint’s nature makes all forms of damages integral to the claim rather than incidental. Jurisdiction is judicially conferred based on the complaint’s allegations, which serve as the ultimate facts for this determination.
Supreme Court’s Precedents Applied
In Mendoza v. Soriano, the Court ruled that claims for damages, regardless of type, should be summed up as the basis for jurisdiction when damages constitute the main cause of action. The same principle was reiterated in Iniego v. Purganan, which clarified that all damages claimed, even if different in nature or arising from separate causes, de
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Case Syllabus (G.R. No. 173915)
Facts of the Case
- On April 5, 2004, respondent Vita N. Kalashian filed a complaint for damages (Civil Case No. 5794-R) with the Regional Trial Court (RTC) of Baguio City, Branch 60, naming petitioners Irene and Reynaldo Sante as defendants.
- The complaint alleged that petitioner Irene Sante uttered offensive and scandalous words against the respondent at the Police Station of Natividad, Pangasinan, in the presence of other individuals and police officers.
- The words alleged, when translated to English, involved offensive sexual remarks directed at the respondent and her friend and personal security guard, Albert Gacusan, who was a suspect in the killing of petitioners’ close relative.
- Further, petitioners were accused of telling people in Natividad that respondent was protecting and supporting the suspects in the aforesaid killing.
- Respondent sought moral damages amounting to P300,000.00; exemplary damages of P50,000.00; attorney’s fees of P50,000.00; litigation expenses of P20,000.00; and other costs of suit.
- Petitioners filed a Motion to Dismiss on the basis that the Municipal Trial Court in Cities (MTCC), not the RTC, had jurisdiction since the claim for moral damages did not exceed the MTCC’s jurisdictional amount after excluding exemplary damages in the computation.
Procedural History and Lower Court Decisions
- The trial court denied the motion to dismiss, ruling in line with the Supreme Court precedent in Movers-Baseco Integrated Port Services, Inc. v. Cyborg Leasing Corporation, holding the total claim at P420,000.00 which was above the MTCC’s jurisdictional ceiling outside Metro Manila.
- The RTC also denied petitioners’ motion for reconsideration reiterating its earlier ruling.
- On August 2, 2004, petitioners filed a Petition for Certiorari and Prohibition with the Court of Appeals (CA), docketed as CA-G.R. SP No. 85465, contesting the RTC’s jurisdiction.
- Respondent and her husband later filed an Amended Complaint increasing the moral damages claim from P300,000.00 to P1,000,000.00.
- Petitioners filed another Motion to Dismiss with Answer Ad Cautelam and Counterclaim; this was again denied by the RTC on September 17, 2004.
- Petitioners filed a second Petition for Certiorari and Prohibition before the Court of Appeals, docketed as CA-G.R. SP No. 87563, contending that the amendment was made solely to confer jurisdiction.
- The Court of Appeals Seventh Division in CA-G.R. SP No. 85465 granted the petition and dismissed the complaint for lack of jurisdiction, ruling that MTCC had jurisdiction with the original claim at P300,000.00, excluding exemplary damages which were incidental.
- The Court of Appeals Seventeenth Division later reversed this and affirmed the RTC’s denial of the motion to dismiss, ruling the total sum of damages claimed must be considered in determining jurisdiction, allowing the amended claim of P1,000,000.00.
Issues Presented
- Whether the RTC of Baguio City, Branch 60, acquired jurisdiction over the case involving damages amounting to P300,000.00.
- Whether the RTC committed grave abuse of discretion when it allowed the complainant to amend the complaint, increasing the damages claim to P1,000,000.00, despite the pending petition for certiorari before the Court