GR 28589; (January, 1973) (Digest)
G.R. No. L-28589 January 8, 1973
RAFAEL ZULUETA, ET AL., plaintiffs-appellees, vs. PAN AMERICAN WORLD AIRWAYS, INC., defendant-appellant.
FACTS
The plaintiffs, the Zulueta family, filed a complaint for damages against Pan American World Airways after Rafael Zulueta was off-loaded from a flight. The defendant airline, in its answer, interposed a counterclaim for P12,000. After a decision was rendered, both parties moved for reconsideration. Subsequently, the defendant filed a new petition seeking to annul the proceedings and dismiss the complaint on jurisdictional grounds. It argued that the plaintiffs’ complaint sought recovery of only P5,502.85 in specified actual damages, and that the unspecified claims for moral damages and attorney’s fees should not be considered in determining the jurisdictional amount. Since the jurisdictional threshold for Courts of First Instance at the time was more than P10,000, the defendant contended the trial court lacked jurisdiction.
ISSUE
The primary issue is whether the trial court had jurisdiction over the plaintiffs’ complaint, considering the amount of the specified damages and the inclusion of claims for moral damages and attorney’s fees.
RULING
The Supreme Court upheld the trial court’s jurisdiction. First, it rejected the defendant’s argument that unspecified damages cannot be considered for jurisdictional purposes, noting the defendant cited no supporting doctrine. Crucially, the Court ruled that a claim for moral damages is not susceptible of pecuniary estimation. Citing Article 2217 of the Civil Code, the Court emphasized that moral damages, though incapable of precise computation, are recoverable and fall within the original jurisdiction of Courts of First Instance over actions “not capable of pecuniary estimation.” Furthermore, the Court established an independent and alternative ground for jurisdiction: the defendant’s own counterclaim for P12,000. Jurisprudence holds that a compulsory counterclaim which exceeds the jurisdictional amount confers jurisdiction on the court, regardless of the amount in the original complaint. The defendant, by actively participating in the trial and seeking affirmative relief through its counterclaim and motion for reconsideration, was also estopped from challenging jurisdiction. The Court found no merit in the jurisdictional challenge and proceeded to deny the substantive grounds for reconsideration, affirming the findings of the trial court based on the credibility of the witnesses and the evidence.