UNITED OVERSEAS BANK VS ROS(pleadings docket fees)

FACTS:

Petitioner is a banking institution duly authorized as such under Philippine laws. Private
respondent Rosemoor Mining and Development Corporation, on the other hand, is a domestic
corporation likewise duly authorized by the Philippine laws to engage in mining operation. On 5
August 1998, private respondent filed an action for damages, accounting, release of the balance
of the loan and machinery and annulment of foreclosure sale against petitioner before the RTC
of Manila, Branch 33. The case was docketed as Civil Case No. 98-90089. In its
Complaint, private respondent alleged that it obtained a loan from petitioner in the amount
of P80,000,000.00 in order to raise the needed capital for the importation of machineries
necessary for its operation. The said loan was secured by two Real Estate Mortgage Contracts
over several parcels of land situated in the Provinces of Bulacan and Nueva Ecija. The
arrangement agreed to by the parties was for the petitioner to handle on behalf of the private
respondent the amount of P50,000,000.00 while the loan balance of P30,000,000.00 will be
released by petitioner to private respondent as a revolving credit line. Petitioner, however,
allegedly mishandled the proceeds of the loan causing serious financial injury to private
respondent. Petitioner then filed an Urgent Motion to Dismiss the private respondent's
complaint on the ground of improper venue since the said complaint included the prayer for
the nullification of the foreclosure of real estate mortgage, a real action which must be lodged
before the RTC of the place where the property or one of the properties is situated.
Consequently, the private respondent amended its Complaint, this time praying for Accounting,
Release of the Balance of the Loan and Damages. After a failed 2 nd motion to dismiss a third
Motion to was filed by the petitioner with the Manila RTC this time raising the issue of
jurisdiction. In its latest Motion to Dismiss, petitioner claimed that private respondent failed to
specify the amount of damages, either in the body or the prayer of its Second Amended
Complaint, in order to evade the payment of the docket fees. As a result, the Manila RTC
cannot acquire jurisdiction over the main action, which should be dismissed.

ISSUE: W/N the failure of the private respondent to pay docket fees warrants dismissal of the
case

HELD:

No. The failure of the private respondent to pay docket feel does not warrant the dismissal of
the case. the rule is clear and simple. In case where the party does not deliberately intend to
defraud the court in payment of docket fees, and manifests its willingness to abide by the rules
by paying additional docket fees when required by the court, the liberal doctrine enunciated in
Sun Insurance and not the strict regulations set in Manchester will apply. In the case at bar, it
was not shown that the private respondent, in failing to state the exact amount of damages it
was claiming in its Second Amended Complaint intended to defraud the court of the docket
fees due. In the first place, upon filing of the original Complaint, the private respondent paid
docket fees in the amount of P42,000.00. Clearly, the circumstances attendant in Manchester,
that prompted this Court to dismiss the case then before it, are wanting herein. Based on the
foregoing, it is but proper therefore, that this case should not be dismissed but be allowed to
continue until judgment, and the private respondent's unpaid docket fee should be considered
as a lien on any monetary judgment in its favor.

PANTRANCO NORTH EXPRESS INC VS STANDARD

INSURANCE( jurisdiction totality rule)
Facts:

In the afternoon of October 28, 1984, Crispin Gicale was driving the passenger jeepney owned
by his mother Martina Gicale, respondent herein. It was then raining. While driving north
bound along the National Highway in Talavera, Nueva Ecija, a passenger bus, owned by
Pantranco North Express, Inc., petitioner, driven by Alexander Buncan, also a petitioner, was
trailing behind. When the two vehicles were negotiating a curve along the highway, the
passenger bus overtook the jeepney. In so doing, the passenger bus hit the left rear side of the
jeepney and sped away. Crispin reported the incident to the Talavera Police Station and
respondent Standard Insurance Co., Inc. (Standard), insurer of the jeepney. The total cost of the
repair was P21,415.00, but respondent Standard paid only P8,000.00. Martina Gicale
shouldered the balance of P13,415.00. Thereafter, Standard and Martina, respondents,
demanded reimbursement from petitioners Pantranco and its driver Alexander Buncan, but
they refused. This prompted respondents to file with the Regional Trial Court (RTC), Branch 94,
Manila, a complaint for sum of money. In their answer, both petitioners specifically denied the
allegations in the complaint and averred that it is the Metropolitan Trial Court, not the RTC,
which has jurisdiction over the case. The RTC and then the CA ruled in favor of the respondents.

ISSUE: W/N the RTC has jurisdiction over the subject matter of the action

HELD:

Yes, the RTC has substancial jurisdiction over the case. The "totality rule" as exemplified by
Section 33 (1) of B.P. Blg.129 which states, among others, that "where there are several claims
or causes of action between the same or different parties, embodied in the same complaint, the
amount of the demand shall be the totality of the claims in all the causes of action, irrespective
of whether the causes of action arose out of the same or different transactions." As previously
stated, respondents' cause of action against petitioners arose out of the same transaction.
Thus, the amount of the demand shall be the totality of the claims. Respondent Standard's
claim is P8,000.00, while that of respondent Martina Gicale is P13,415.00, or a total
of P21,415.00. Section 19 of B.P. Blg. 129 provides that the RTC has "exclusive original
jurisdiction over all other cases, in which the demand, exclusive of interest and cost or the value
of the property in controversy, amounts to more than twenty thousand pesos (P20,000.00)."
Clearly, it is the RTC that has jurisdiction over the instant case. It bears emphasis that when the
complaint was filed, R.A. 7691 expanding the jurisdiction of the Metropolitan, Municipal and
Municipal Circuit Trial Courts had not yet taken effect. It became effective on April 15, 1994.

INIEOGO VS PURNAGAN(Totality rule)

FACTS:

On 1 March 2002, private respondent Fokker Santos filed a complaint for quasi-delict and
damages against Jimmy T. Pinion, the driver of a truck involved in a traffic accident, and against
petitioner Artemio Iniego, as owner of the said truck and employer of Pinion. The complaint
stemmed from a vehicular accident that happened on 11 December 1999, when a freight truck
allegedly being driven by Pinion hit private respondent's jitney which private respondent was
driving at the time of the accident. On 24 August 2002, private respondent filed a Motion to
Declare defendant in Default allegedly for failure of the latter to file his answer within the final
extended period. On 28 August 2002, petitioner filed a Motion to Admit and a Motion to
Dismiss the complaint on the ground, among other things, that the RTC has no jurisdiction over
the cause of action of the case. The plaintiff argues that this court has exclusive jurisdiction
because the cause of action is the claim for damages, which exceeds P400,000.00. The
complaint prays for actual damages in the amount of P40,000.00, moral damages in the
amount of P300,000.00, and exemplary damages in the amount of P150,000.00. Excluding
attorney's fees in the amount of P50,000.00, the total amount of damages being claimed
is P490,000.00. The motion to dismiss was denied.

ISSUE: W/N the RTC has substantive jurisdiction over the action

HELD:

Despite our concurrence in petitioner's claim that actions for damages based on quasi-delict are
actions that are capable of pecuniary estimation, we find that the total amount of damages
claimed by the private respondent nevertheless still exceeds the jurisdictional limit
of P400,000.00 and remains under the jurisdiction of the RTC. Petitioner argues that in actions
for damages based on quasi-delict, claims for damages arising from a different cause of action
(i.e., other than the fault or negligence of the defendant) should not be included in the
computation of the jurisdictional amount. According to petitioner, the moral and exemplary
damages claimed by the respondents in the case at bar are not direct and proximate
consequences of the alleged negligent act. Petitioner points out that the complaint itself stated
that such moral and exemplary damages arose from the alleged refusal of defendants to honor
the demand for damages, and therefore there is no reasonable cause and effect between the
fault or negligence of the defendant and the claim for moral and exemplary damages. If the
claims for moral and exemplary damages are not included in the computation for purposes of
determining jurisdiction, only the claim for actual damages in the amount of P40,000.00 will be
considered, and the MeTC will have jurisdiction. We cannot give credence to petitioner's
arguments. The distinction he made between damages arising directly from injuries in a quasi-
delict and those arising from a refusal to admit liability for a quasi-delict is more apparent than
real, as the damages sought by respondent originate from the same cause of action: the quasi-
delict. The fault or negligence of the employee and the juris tantum presumption of negligence
of his employer in his selection and supervision are the seeds of the damages claimed, without
distinction. 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.
Jurisdiction in the case at bar remains with the RTC, considering that the total amount claimed,
inclusive of the moral and exemplary damages claimed, is P490,000.00.

BRIONES V CA(Exclusive venue)

FACTS:

The instant case arose from a complainant for nullity of a mortgage contract, promisory note,
loan agreement, forclosure of mortgage, cancelation of transfer certificate of title and against a
lending company. The plaintiff alleged that he is the owner of a real property which was soght
to be foreclosed by the defendant despite his not having contracted any loans from the
defendant. He claimed that he has been living and working in Vietnam since 2007. Essentially,
he assailed the validity of the foregoing contract claiming his signature to be forged. The
defendant filed a motion to dismiss on the ground of improper venue. The motion relied on the
venue stipulation in the assailed contracts that all legal actions srising from the same shall be
brought only in the proper court of Makati City.

ISSUE: W/N the exclusive venue stipulation is binding on the parties

HELD:

The Court held that in the cases where the complaint assails only the terms, conditions, and/or
coverage of a written instrument and not its validity of the instrument, the exclusive venue
stipulation shall still be binding on the parties, and thus the complaint may properly be
dismissed on the ground of improper venue. However, a complaint assailing the validity of a
written instrument itself should not be bound by the exclusive venue stipulation contained
therein and should be filed in accordance with the general rules of venue. The plaintiff
therefore, is not bound to file the action in Makati City.