Title
Sante vs. Claravall
Case
G.R. No. 173915
Decision Date
Feb 22, 2010
Defamation case: RTC jurisdiction upheld as total damages (P420k) exceeded MTCC limit; amendment to increase claim allowed. SC affirmed CA/RTC rulings.

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

  1. 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.
  2. 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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