GR 136109; (August, 2002) (Digest)
G.R. No. 136109 ; August 1, 2002
RADIO COMMUNICATIONS OF THE PHILIPPINES, INC., petitioner, vs. COURT OF APPEALS and MANUEL DULAWON, respondents.
FACTS
On June 18, 1997, private respondent Manuel Dulawon filed a complaint for breach of contract of lease with damages against petitioner Radio Communications of the Philippines, Inc. (RCPI) with the Regional Trial Court (RTC) of Tabuk, Kalinga. Petitioner filed a motion to dismiss the complaint for lack of jurisdiction, contending that the Municipal Trial Court (MTC) had jurisdiction because the complaint was essentially for the collection of unpaid rentals amounting to P84,000.00, which did not exceed the P100,000.00 jurisdictional amount for RTCs. The RTC denied the motion to dismiss and the subsequent motion for reconsideration. Petitioner then filed a petition for certiorari with the Court of Appeals, which dismissed the petition. The motion for reconsideration was also denied, prompting this petition for review.
ISSUE
Whether or not the Regional Trial Court has jurisdiction over the complaint filed by private respondent.
RULING
Yes, the Regional Trial Court has jurisdiction. The Supreme Court denied the petition and affirmed the decision of the Court of Appeals. The Court held that the nature of the principal action or remedy sought determines jurisdiction. An examination of the allegations in the complaint revealed that the cause of action was for breach of contract, specifically aimed at enforcing a three-year lease contract. The action was primarily one for specific performance, as it sought to enforce the contract, with the claim for unpaid rentals and damages being merely incidental or a consequence of the main relief. Following the precedent in Manufacturer’s Distributors, Inc. v. Siu Liong, actions for specific performance are incapable of pecuniary estimation and fall under the exclusive original jurisdiction of the Regional Trial Court pursuant to Section 19(1) of Batas Pambansa Blg. 129, as amended. Therefore, the RTC correctly denied the motion to dismiss.