G.R. No. L-66620 September 24, 1986
REMEDIO V. FLORES, petitioner, vs. HON. JUDGE HEILIA S. MALLARE-PHILLIPPS, IGNACIO BINONGCAL & FERNANDO CALION, respondents.

FACTS

Petitioner Remedio V. Flores filed a complaint in the Regional Trial Court (RTC) against respondents Ignacio Binongcal and Fernando Calion. The complaint alleged two separate causes of action: the first was against Binongcal for P11,643.00, representing the unpaid cost of truck tires purchased on credit from August to October 1981; the second was against Calion for P10,212.00, representing the unpaid cost of truck tires purchased on credit from March 1981 to January 1982. The total aggregate demand was P21,855.00.
Respondent Binongcal filed a Motion to Dismiss on the ground of lack of jurisdiction, arguing that his individual indebtedness of P11,643.00 was below the P20,000.00 jurisdictional threshold for the RTC under BP 129. He contended that his obligation was separate and distinct from that of Calion. Respondent Calion joined the motion. The RTC granted the motion and dismissed the complaint for lack of jurisdiction.

ISSUE

Whether the Regional Trial Court has jurisdiction over the complaint based on the totality of the separate claims against two different defendants.

RULING

The Supreme Court affirmed the RTC’s order of dismissal, ruling that it lacked jurisdiction. The Court explained the application of the “totality rule” under Section 33(1) of BP 129 and Section 11 of the Interim Rules. This rule states that where there are several claims in one complaint, the jurisdictional amount is the aggregate sum of all money demands.
However, the Court held that this totality rule is subject to the requirements for permissive joinder of parties under Section 6, Rule 3 of the Rules of Court. Permissive joinder is allowed only when the right to relief arises out of the same transaction or series of transactions, and a common question of law or fact exists among all the parties joined.
In this case, the claims against Binongcal and Calion were separate and distinct. They arose from different sets of transactions occurring at different times. There was no allegation that the obligations arose from the same transaction or series of transactions, nor was a common question of law or fact present. Consequently, there was a misjoinder of parties. Since the claims could not be permissively joined, the totality rule did not apply to aggregate the amounts. Each separate claim had to furnish the jurisdictional test. As each individual claim was below P20,000.00, the RTC correctly dismissed the complaint for lack of jurisdiction.