G.R. No. 140746; March 16, 2005
PANTRANCO NORTH EXPRESS, INC., and ALEXANDER BUNCAN, Petitioners, vs. STANDARD INSURANCE COMPANY, INC., and MARTINA GICALE, Respondents.

FACTS

On October 28, 1984, a passenger bus owned by Pantranco North Express, Inc. and driven by Alexander Buncan overtook and hit the left rear side of a jeepney owned by Martina Gicale and driven by her son in Talavera, Nueva Ecija. The bus sped away after the incident. The jeepney was insured by Standard Insurance Company, Inc., which paid P8,000.00 for repairs, while Martina Gicale shouldered the balance of P13,415.00. Respondents demanded reimbursement from petitioners, who refused payment, prompting the filing of a complaint for sum of money before the Regional Trial Court (RTC) of Manila.
Petitioners, in their answer, specifically denied the allegations and contested the RTC’s jurisdiction, arguing that the individual claims of Martina Gicale (P13,415.00) and Standard Insurance (P8,000.00) fell within the exclusive original jurisdiction of the Metropolitan Trial Court. The RTC ruled in favor of respondents, ordering petitioners to pay the amounts with interest, attorney’s fees, and costs. The Court of Appeals affirmed the RTC decision, applying the totality rule to determine jurisdiction.

ISSUE

The primary issues are: (1) whether the RTC had jurisdiction over the complaint; (2) whether petitioners are liable for quasi-delict; and (3) whether petitioners were deprived of due process.

RULING

The Supreme Court denied the petition and affirmed the Court of Appeals. On jurisdiction, the Court held that the RTC properly exercised jurisdiction under the totality rule. Section 19 of Batas Pambansa Blg. 129 provides that the jurisdictional amount is determined by the aggregate sum of all claims in the complaint. The total claim of P21,415.00 exceeded the P20,000.00 threshold for the RTC’s jurisdiction at the time of filing. Furthermore, permissive joinder of parties under Section 6, Rule 3 of the Rules of Court was correctly applied, as both respondents’ claims arose from the same vehicular accident, involving a common question of fact—the determination of fault or negligence causing the damage.
On the merits, the Court sustained the findings of the lower courts that petitioners are liable for quasi-delict under Article 2176 of the Civil Code. The factual conclusions of the trial court, affirmed by the Court of Appeals, are binding and supported by evidence, showing no arbitrariness. Petitioners failed to rebut the presumption of negligence established by the bus driver’s act of hitting the jeepney and fleeing the scene.
Finally, petitioners were not denied due process. The essence of due process is the opportunity to be heard. Records show petitioners filed an answer, participated in hearings, and were granted several postponements. Their failure to appear during scheduled hearings for the presentation of their evidence, despite notice, constituted a waiver. The trial court’s order deeming the case submitted for decision was proper, as petitioners were afforded a fair opportunity to explain their side.