G.R. No. L-55954. December 19, 1981. FERMIN CASOCOT and CEFERINA CASOCOT, for themselves and in behalf of DENNIS CARMELO CASOCOT, petitioners, vs. THE HONORABLE CIPRIANO V. VAMENTA, JR., District Judge, Court of First Instance, Branch III, of Negros Oriental; and ELADIO DIOKO, VIRGINIA CAPULSO, PERLA DULALAS, CELIA FE GAMO, AMBROCIO PINERO, NAPOLEON CAPULSO, ESTER GARGANTIEL, SOCORRO ARROYO, FELINA VIAJEDOR, AVELINA ELNAR, ALFREDO VIAJEDOR, MAGDALENA ESTINOSO, RUFINO AGUINOD, and ONOFRE CORPUZ, Minister of Education and Culture, respondents.
FACTS

Petitioners Fermin and Ceferina Casocot, on behalf of their son Dennis Carmelo Casocot, filed a complaint for damages against various school officials and the Minister of Education and Culture. The action was rooted in Article 27 of the New Civil Code, which pertains to liability for any person who willfully causes loss or injury to another in a manner contrary to morals, good customs, or public policy. The core grievance involved the alleged malicious and unlawful acts of the respondents in connection with the academic honors due to Dennis Carmelo Casocot.
The petitioners claimed to have exhausted administrative remedies, having appealed to respondent Division Superintendent Eladio Dioko. Following consultation with the Regional Director, Dioko confirmed via a wire, citing MEC Order No. 17, s. 1978, that Dennis Carmelo Casocot was entitled to and would be designated as “first honors.” Despite this administrative determination, the petitioners pursued the civil case for damages. The respondent trial judge, however, issued orders dismissing the case, prompting this petition.

ISSUE

The primary issue is whether the respondent trial court correctly dismissed the complaint for damages filed by the petitioners.

RULING

The Supreme Court set aside the trial court’s dismissal orders and directed the judge to proceed with the trial against the respondents, except the Ministry of Education and Culture and Division Superintendent Eladio Dioko. The legal logic is clear. First, the complaint is properly within the jurisdiction of the Court of First Instance (now Regional Trial Court). Jurisdiction is determined by the allegations in the complaint and the relief sought. Paragraph 7 of the complaint explicitly alleges claims for compensatory damages of not less than P5,000.00 for each petitioner, incidental expenses to be proven at trial, and exemplary damages. The aggregate claim, therefore, exceeds the P10,000.00 threshold for the court’s jurisdiction at the time.
Second, the cause of action under Article 27 of the Civil Code is distinct from any administrative matter. The exhaustion of administrative remedies was satisfied when the petitioners appealed to Superintendent Dioko and obtained a ruling in their favor regarding the honors designation. This administrative resolution did not preclude the separate civil action for damages based on the alleged willful and injurious acts that caused “tortured feelings, mental anguish, public contempt and humiliation.” The civil liability for such damages exists independently. Consequently, the trial court erred in dismissing the case and was ordered to proceed with the trial on the merits against the individual school officials. The petition was denied as to the Ministry and Dioko, as per a prior resolution, for lack of merit.