G.R. No. 139031 ; October 18, 2004
MARIE ANTOINETTE R. SOLIVEN, petitioner, vs. FASTFORMS PHILIPPINES, INC., respondent.

FACTS

Petitioner Marie Antoinette Soliven filed a complaint for sum of money with damages against respondent Fastforms Philippines, Inc., before the Regional Trial Court (RTC) of Makati. She alleged that on June 2, 1993, respondent, through its president Dr. Eduardo Escobar, obtained a loan of ₱170,000.00 from her, payable within 21 days with 3% interest, as evidenced by a promissory note and a postdated check for ₱175,000.00. Respondent later advised against depositing the check due to insufficient funds and proposed a “roll-over” with a 5% monthly interest, to which petitioner agreed. Respondent subsequently issued several checks totaling ₱76,250.00 as partial interest payments. After repeated demands for payment of the principal and remaining interests were refused, petitioner filed her complaint, praying for actual damages of ₱195,155.00, moral damages, exemplary damages, and attorney’s fees.
Respondent, in its answer, denied obtaining a loan and claimed lack of authority of its president to contract the loan. After trial, the RTC rendered a decision in favor of petitioner, ordering respondent to pay the loan amount with interest and attorney’s fees. Only then, in a motion for reconsideration, did respondent question the RTC’s jurisdiction for the first time, arguing that since the principal demand (₱195,155.00) did not exceed ₱200,000.00, jurisdiction lay with the Metropolitan Trial Court (MeTC) under R.A. No. 7691 . The RTC denied the motion, ruling it had jurisdiction and that respondent was estopped from raising the issue.

ISSUE

Whether the Regional Trial Court had jurisdiction over the case.

RULING

Yes, the RTC had jurisdiction. The Supreme Court clarified that for purposes of determining jurisdiction under R.A. No. 7691 , the amount of the demand is the totality of the claims in the complaint, including damages and attorney’s fees when they are main causes of action. Here, petitioner’s complaint sought not only ₱195,155.00 in actual damages but also ₱200,000.00 in moral damages, ₱100,000.00 in exemplary damages, and ₱100,000.00 in attorney’s fees. Since the claims for moral and exemplary damages were pleaded as separate causes of action arising from the alleged breach of contract and willful refusal to pay, they are not merely incidental. Therefore, the total claim far exceeded the ₱200,000.00 threshold for RTC jurisdiction in Metro Manila.
Moreover, respondent was estopped from challenging jurisdiction. Jurisdiction may be assailed at any time, but a party who voluntarily submits to the court’s authority by seeking affirmative relief is barred from later repudiating that jurisdiction. Respondent actively participated in the trial by filing an answer with counterclaim, presenting evidence, and fully litigating its case. Having invoked the RTC’s jurisdiction to obtain a favorable judgment, respondent cannot, after an adverse decision, question the court’s authority. The Court frowns upon this undesirable practice. Consequently, the Court of Appeals’ decision was reversed, and the RTC’s judgment was reinstated.