G.R. No. 143951 October 25, 2005
Norma Mangaliag and Narciso Solano, Petitioners, vs. Hon. Edelwina Catubig-Pastoral, Judge of the Regional Trial Court, 1st Judicial Region, San Carlos City, (Pangasinan), Branch 56 and Apolinario Serquina, Jr., Respondents.

FACTS

Private respondent Apolinario Serquina, Jr. filed a complaint for damages against petitioners Norma Mangaliag and Narciso Solano before the Regional Trial Court (RTC). The complaint arose from a vehicular accident allegedly caused by the negligence of Solano, Mangaliag’s employee. Serquina claimed actual damages of ₱71,392.00 for medical expenses, moral damages of ₱500,000.00 for physical injuries and depression, lost income of ₱25,000.00, and attorney’s fees. After pre-trial and the commencement of trial, petitioners, through new counsel, filed a motion to dismiss on the ground of lack of jurisdiction. They argued that jurisdiction lay with the Municipal Trial Court (MTC) because the principal claim for actual damages (₱71,392.00) was below the jurisdictional threshold for the RTC, and that other damages like moral damages should be excluded from the jurisdictional computation.
The RTC denied the motion to dismiss, citing Administrative Circular No. 09-94 and the case of Ong vs. Court of Appeals. The trial court held that in an action where the claim for damages is the main cause of action, the total amount of all damages claimed, including moral damages, determines jurisdiction. Petitioners’ motion for reconsideration was likewise denied, prompting them to file the instant petition for certiorari.

ISSUE

Whether the Regional Trial Court correctly assumed jurisdiction over the complaint for damages by considering the totality of the claims, including moral damages, and not just the claim for actual damages.

RULING

The Supreme Court dismissed the petition and affirmed the RTC’s orders. The Court held that the RTC correctly exercised jurisdiction. The legal logic is anchored on the proper interpretation of jurisdictional rules under Batas Pambansa Blg. 129, as amended, and Administrative Circular No. 09-94. In actions for damages where the claim for damages is the main cause of action, the aggregate sum of all the damages claimed of whatever kind—actual, moral, exemplary, nominal, and attorney’s fees—determines which court has jurisdiction. This aggregate amount is considered the “total claim” or “sum demanded” for jurisdictional purposes.
The Court rejected petitioners’ argument that only the actual damages constitute the principal demand. In a quasi-delict case like the one at bar, the cause of action is the negligent act causing injury, and the claims for actual and moral damages are distinct, primary reliefs arising directly from that single cause of action. Moral damages in such cases are not merely incidental; they are recoverable by law (Article 2219 of the Civil Code) as a direct consequence of the quasi-delict. Since the total amount claimed (exceeding ₱596,000.00 when including all items) was above the jurisdictional amount for the MTC at the time, jurisdiction was properly vested in the RTC. The ruling in Movers-Baseco was distinguished as involving a different procedural context. The defense of lack of jurisdiction was also deemed waived as it was raised only after petitioners had already actively participated in the trial by presenting their evidence.