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CIVIL PROCEDURE | B2015 CASES

Iniego v. Hon. Judge Purganan


March 24, 2006 Chico-Nazario alycat

SUMMARY: Defendant (herein petitioner) to an action based on QD filed a Motion to Dismiss the action against him pending before the RTC on the ground that such court has no jurisdiction over it. Private respondent asserts otherwise. Respondent judge ruled in favor of the latter, claiming that the RTC has exclusive original jurisdiction over the action. CA affirmed. SC affirmed insofar as jurisdiction remains with the RTC, considering that the total amount claimed is P490,000 DOCTRINE: Actions for damages based on quasi-delict are actions based on pecuniary estimation. As such, they fall within the jurisdiction of either the RTC or the municipal courts, depending on the amount of (all kinds) damages claimed. FACTS: Petition for review on certiorari under Rule 45 Private Respondent Fokker Santos (Everyone, meet Fokker! :D) filed a complaint for quasi-delict and damages against Jimmy T. Pinion, driver of the truck involved in the traffic accident, and against Artemio Iniego (Petitioner), owner of the said truck and employer of Pinion. The complaint stemmed from a vehicular accident in 1999, where a freight truck driven by Pinion hit PRs jitney which Santos was driving at the time of the accident. (No details given.) The total amount of damages claimed is P490,000 Santos filed a Motion to Declare Iniego in default for failure of the latter to file his answer within the final extended period. Iniego filed a Motion to Admit and a Motion to Dismiss the complaint on the ground that the RTC has no jurisdiction over the cause of action. Judge Guillermo G. Purganan of the RTC issued the assailed Omnibus Order, which ruled: o The Motion to Declare Iniego in default must be denied, as Iniegos failure to file his answer was because the Order was sent to the wrong address, and so Iniego never received it. o The main cause of action is not the claim for damages, but quasi-delict. Damages are claimed only as a result of the

alleged fault or negligence of both defendants under Art. 2176 in the case of Pinion, and Art. 2180 for Iniego. But since fault or negligence cannot be the subject of pecuniary estimation, this court (RTC) has exclusive jurisdiction. Iniego moved for reconsideration, which was denied by the CA. Hence, this petition.

ISSUES + RATIO: 1. WON actions for damages based on QD are capable of pecuniary estimation YES They are primarily and effectively actions for the recovery of a sum of money for the damages suffered because of defendants alleged tortious acts, therefore capable of pecuniary estimation. According to herein Judge Purganan, since fault or negligence in QDs cannot be the subject of pecuniary estimation, the RTC has jurisdiction. This is erroneous. It is crystal cear from BP Blg. 129, as amended by RA 7691, that what must be determined to be capable or incapable of pecuniary estimation is not the cause of action, but the subject matter of the action. A cause of action is the delict or wrongful act or omission committed by the defendant in violation of the primary rights of the plaintiff. On the other hand, the subject matter of the action is the physical facts, the thing real or personal. in relation to which the suit is prosecuted. In the case of Lapitan v. Scandia, Justice JBL Reyes, wrote, on the issue of determining whether the subject matter of an action is capable of pecuniary estimation (rephrased): This Court has adopted the criterion of first ascertaining the nature of the principal action or remedy sought. If it is for the recovery of a sum of money, the claim is capable of pecuniary estimation. And whether jurisdiction is in the municipal courts or in the RTCs would depend on the amount of the claim. However, where the basic issue is something other than the right to recover a sum of money, where the money claim is purely incidental to, or a consequence of the principal relief sought (ex. specific performance, actions for support, etc.) the subject of litigation may not be estimated in terms of money. Actions for damages based on QDs are actions for the recovery of a sum of money for the damages suffered because of the defendants alleged tortious acts. The damages represent the monetary equivalent of the injury, thus sought to be recovered by the plaintiff. This money claim is the principal relief sought and is not merely incidental thereto or a consequence thereof.

CIVIL PROCEDURE | B2015 CASES

Fault or negligence is not actionable by itself. For such fault or negligence to be actionable, there must be a resulting damage to a third person. The relief available is for the reparation, restitution, or payment of such damage, without which, the alleged offended party has no cause of action or relief. The fault or negligence, therefore, is inextricably intertwined with the claim for damages, and there can be no action based on QD without a claim for damages. 2. WON the amount of damages is within the jurisdiction of the RTC YES It is the claim for all kinds of damages that is the basis of determining the jurisdiction of courts, whether the claim for damages arises from the same or from different causes of action. The Court concurs with Iniego that actions for damages are actions that are capable of pecuniary estimation. However, the total amount of damages still exceeds the jurisdictional limit of P400,000 and remains under the jurisdiction of the RTC. The distinction made between damages arising from injuries in a QD (actual damages) and those arising from a refusal to admit liability for a QD (moral and exemplary damages), which Iniego claims, is more apparent than real, as the damages sought originate from the same cause of action: the QD. (Note: The basis for the moral and exemplary damages here is supposedly Iniegos refusal to acknowledge his liability and pay the corresponding damages. The basis for the actual damages is the accident itself. ) The fault or negligence of the employee and the juris tantum presumption of negligence of his employer are the seeds of the damages claimed, without distinction. Even assuming that the claims for moral and exemplary damages arose from a cause of action other than the QD, their inclusion in the computation of damages for jurisdictional purposes is still proper. Rule 2, Sec. 5 (d) provides that where the claims in joined causes of action are principally for recovery of money, the aggregate amount claimed shall be the test of jurisdiction. Hence, whether or not the different claims for damages are based on a single cause of action or different causes of action, it is the total amount thereof which shall govern. HELD: CA affirmed insofar as jurisdiction remains with the RTC, considering that the total amount claimed is P490,000