G.R. No. 131755 October 25, 1999
MOVERS-BASECO INTEGRATED PORT SERVICES, INC., petitioner, vs. CYBORG LEASING CORPORATION, respondent.

FACTS

Cyborg Leasing Corporation filed a complaint for “Damages with Prayer for a Writ of Replevin” against Conpac Warehousing, Inc. and Movers-Baseco Integrated Port Services, Inc. before the Metropolitan Trial Court (MTC). Cyborg alleged it leased a Nissan forklift to Conpac, which failed to pay rentals starting April 1995. Petitioner Movers-Baseco later took control of Conpac’s operations and seized the forklift, ignoring Cyborg’s demand for its return. The complaint prayed for: (a) a writ of replevin to take possession of the forklift; (b) after trial, judgment ordering defendants to pay P11,000 monthly as actual damages from April 9, 1995, until repossession, P1,000,000 as exemplary damages, and P50,000 as attorney’s fees; and (c) in the alternative, if the equipment could not be seized, payment of its actual market value of P150,000, exclusive of the other damages. The MTC issued a writ of replevin. Petitioner filed a motion to dismiss on the ground of lack of jurisdiction, arguing the total claims (P150,000 + P242,000 + P1,000,000 + P50,000 = P1,442,000) exceeded the MTC’s jurisdictional amount. The MTC dismissed the complaint for lack of jurisdiction, holding that the total claims, including specified damages, determined jurisdiction. The MTC denied Cyborg’s motion for reconsideration and directed the sheriff to return the forklift to petitioner. Cyborg then filed a petition for certiorari and prohibition with the Regional Trial Court (RTC). The RTC granted Cyborg’s application for a preliminary injunction, enjoining the enforcement of the MTC’s order to return the forklift, and later rendered a decision annulling the MTC’s orders and reinstating the complaint. Petitioner moved for reconsideration, which was denied.

ISSUE

Whether the Metropolitan Trial Court correctly dismissed the complaint for lack of jurisdiction based on the total amount of claims, including damages, exceeding its jurisdictional limit.

RULING

Yes. The Supreme Court granted the petition, annulled and set aside the RTC decision, and reinstated the MTC orders dismissing the complaint for lack of jurisdiction. The Court held that in a replevin suit, the value of the personal property sought to be recovered determines jurisdiction. However, if the action is primarily for damages, or damages is one of the causes of action, the amount of such claim shall be considered in determining jurisdiction. In this case, the complaint was denominated as one for “Damages with Prayer for a Writ of Replevin.” The body of the complaint and the prayers showed that Cyborg sought not just the recovery of the forklift but also the recovery of substantial sums as actual, exemplary, and other damages, with the recovery of the property being merely ancillary to the main action for damages. The total claims amounted to P1,442,000, which was beyond the MTC’s jurisdiction. The Court also noted that Cyborg’s petition for certiorari before the RTC was filed out of time, as it was filed 74 days from receipt of the MTC order denying the motion for reconsideration, beyond the 60-day period under the 1997 Rules of Civil Procedure.