GR 166876; (March, 2006) (Digest)
G.R. No. 166876 ; March 24, 2006
ARTEMIO INIEGO, Petitioner, vs. The HONORABLE JUDGE GUILLERMO G. PURGANAN, in his official capacity as Presiding Judge of the Regional Trial Court, Branch 42, City of Manila, and FOKKER C. SANTOS, Respondents.
FACTS
Private respondent Fokker Santos filed a complaint for quasi-delict and damages against petitioner Artemio Iniego and his driver, Jimmy Pinion, arising from a vehicular accident. The complaint sought actual damages of P40,000.00, moral damages of P300,000.00, exemplary damages of P150,000.00, and attorney’s fees, totaling P490,000.00. Petitioner moved to dismiss the case, contending that the Regional Trial Court (RTC) lacked jurisdiction. He argued that actions for damages based on quasi-delict are capable of pecuniary estimation and, since the amount claimed (excluding moral and exemplary damages) did not exceed the P400,000.00 jurisdictional threshold for Metro Manila first-level courts, the case should be heard by the municipal court.
The RTC denied the motion to dismiss, holding that the main cause of action was quasi-delict, which it deemed not capable of pecuniary estimation, thus vesting exclusive jurisdiction in the RTC regardless of the amount claimed. The Court of Appeals affirmed the RTC’s denial of the motion to dismiss, prompting petitioner to elevate the case to the Supreme Court via a petition for review on certiorari.
ISSUE
The primary issue is whether an action for damages based on quasi-delict is capable of pecuniary estimation for purposes of determining jurisdiction between first-level courts and the RTC.
RULING
The Supreme Court ruled that actions for damages based on quasi-delict are indeed capable of pecuniary estimation. The Court clarified that the nature of an action is determined by the allegations in the complaint and the relief sought. An action is considered capable of pecuniary estimation if its primary objective is to recover a sum of money, as is the case in a claim for damages arising from quasi-delict. The cause of action (quasi-delict) and the relief (damages) are inseparable; the damages are the direct result of the negligent act. Consequently, jurisdiction is determined by the total amount of damages claimed, inclusive of moral and exemplary damages.
The Court rejected the petitioner’s argument to exclude moral and exemplary damages from the jurisdictional computation. It held that all damages claimed, regardless of type, must be aggregated if they arise from the same cause of action. Since the total claim of P490,000.00 exceeded the P400,000.00 jurisdictional amount for Metro Manila municipal courts at the time, the RTC correctly exercised jurisdiction. The petition was denied, and the rulings of the lower courts were affirmed.