CASE DIGEST: Iniego vs. Hon. Judge Guillermo Purganan

 

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.

G.R. No. 166876. March 24, 2006.

DOCTRINE:

Jurisdictions; What must be determined to be capable or incapable of pecuniary estimation is not the cause of action, but the subject matter of the action.— Respondent Judge’s observation is erroneous. It is crystal clear from B.P. Blg. 129, as amended by Republic Act No. 7691, that what must be determined to be capable or incapable of pecuniary estimation is not the cause of action, but the subject matter of the action. A cause of action is “the delict or wrongful act or omission committed by the defendant in violation of the primary rights of the plaintiff.” On the other hand, the “subject matter of the action” is “the physical facts, the thing real or personal, the money, lands, chattels, and the like, in relation to which the suit is prosecuted, and not the delict or wrong committed by the defendant.”

Damages; Actions for damages based on quasi-delicts are primarily and effectively actions for the recovery of a sum of money for the damages suffered because of the defendant’s alleged tortious acts.—Actions for damages based on quasi-delicts are primarily and effectively actions for the recovery of a sum of money for the damages suffered because of the defendant’s alleged tortious acts. The damages claimed in such actions represent the monetary equivalent of the injury caused to the plaintiff by the defendant, which are thus sought to be recovered by the plaintiff. This money claim is the principal relief sought, and is not merely incidental thereto or a consequence thereof. It bears to point out that the complaint filed by private respondent before the RTC actually bears the caption “for DAMAGES.”

Subsection (d) of Section 5, Rule 2 of the Rules of Court provides that where the claims in all such joined causes of action are principally for recovery of money, the aggregate amount claimed shall be the test of jurisdiction.—Even assuming, for the sake of argument, that the claims for moral and exemplary damages arose from a cause of action other than the quasi-delict, their inclusion in the computation of damages for jurisdictional purposes is still proper. All claims for damages should be considered in determining the jurisdiction of the court regardless of whether they arose from a single cause of action or several causes of action. Rule 2, Section 5, of the Rules of Court allows a party to assert as many causes of action as he may have against the opposing party. Subsection (d) of said section provides that where the claims in all such joined causes of action are principally for recovery of money, the aggregate amount claimed shall be the test of jurisdiction.

Actions for damages based on quasidelicts are actions that are capable of pecuniary estimation. —Actions for damages based on quasi-delicts are actions that are capable of pecuniary estimation. As such, they fall within the jurisdiction of either the RTC or the municipal courts, depending on the amount of damages claimed. In this case, the amount of damages claimed is within the jurisdiction of the RTC, since it is the claim for all kinds of damages that is the basis of determining the jurisdiction of courts, whether the claims for damages arise from the same or from different causes of action.

FACTS:

On 1 March 2002, private respondent Fokker Santos filed a complaint for quasi-delict and damages against Jimmy T. Pinion, the driver of a truck involved in a traffic accident, and against petitioner Artemio Iniego, as owner of the said truck and employer of Pinion. The complaint stemmed from a vehicular accident that happened on 11 December 1999, when a freight truck allegedly being driven by Pinion hit private respondent’s jitney which private respondent was driving at the time of the accident.

On 28 August 2002, petitioner filed a Motion to Admit and a Motion to Dismiss the complaint on the ground, among other things, that the RTC has no jurisdiction over the cause of action of the case.

On 21 October 2002, public respondent Judge Guillermo G. Purganan issued the assailed Omnibus Order denying the Motion to Dismiss of the petitioner. The RTC explained that the main cause of action is not the claim for damages but quasi-delict. Damages are being claimed only as a result of the alleged fault or negligence of both defendants under Article 2176 of the Civil Code in the case of defendant Pinion and under Article 2180 also of the Civil Code in the case of defendant Iniego. But since fault or negligence (quasidelicts) could not be the subject of pecuniary estimation, the RTC has exclusive jurisdiction.

In the present petition, petitioner claims that actions for damages based on quasidelict are actions that are capable of pecuniary estimation; hence, the jurisdiction in such cases falls upon either the municipal courts or the RTC, depending on the value of the damages claimed.

Petitioner argues further that should the SC find actions for damages capable of pecuniary estimation, then the total amount of damages claimed by the private respondent must exceed P400,000.00 in order that it may fall under the jurisdiction of the RTC. Petitioner asserts, however, that the moral and exemplary damages claimed by private respondent be excluded from the computation of the total amount of damages for jurisdictional purposes because the said moral and exemplary damages arose, not from the quasi-delict, but from the petitioner’s refusal to pay the actual damages.

ISSUE:

WON the RTC has jurisdiction of the case

RULING:

It is crystal clear from B.P. Blg. 129, as amended by Republic Act No. 7691, that what must be determined to be capable or incapable of pecuniary estimation is not the cause of action, but the subject matter of the action. A cause of action is “the delict or wrongful act or omission committed by the defendant in violation of the primary rights of the plaintiff.” On the other hand, the “subject matter of the action” is “the physical facts, the thing real or personal, the money, lands, chattels, and the like, in relation to which the suit is prosecuted, and not the delict or wrong committed by the defendant.”

The case of Lapitan vs. Scandia Inc. is the guiding case in determining whether the subject matter of the action is capable of pecuniary estimation. In Lapitan, the Court spoke:

“In determining whether an action is one the subject matter of which is not capable of pecuniary estimation this Court has adopted the criterion of first ascertaining the nature of the principal action or remedy sought. If it is primarily for the recovery of a sum of money, the claim is considered capable of pecuniary estimation, and whether jurisdiction is in the municipal courts or in the courts of first instance [now Regional Trial Courts] would depend on the amount of the claim. However, where the basic issue is something other than the right to recover a sum of money, where the money claim is purely incidental to, or a consequence of, the principal relief sought like suits to have the defendant perform his part of the contract (specific performance) and in actions for support, or for annulment of a judgment or to foreclose a mortgage, this court has considered such actions as cases where the subject of the litigation may not be estimated in terms of money, and are cognizable exclusively by courts of first instance [now Regional Trial Courts]. x x x.”

Actions for damages based on quasi-delicts are primarily and effectively actions for the recovery of a sum of money for the damages suffered because of the defendant’s alleged tortious acts. The damages claimed in such actions represent the monetary equivalent of the injury caused to the plaintiff by the defendant, which are thus sought to be recovered by the plaintiff. This money claim is the principal relief sought, and is not merely incidental thereto or a consequence thereof. It bears to point out that the complaint filed by private respondent before the RTC actually bears the caption “for DAMAGES.”

Fault or negligence is not actionable by itself. For such fault or negligence to be actionable, there must be a resulting damage to a third person. The relief available to the offended party in such cases is for the reparation, restitution, or payment of such damage, without which any alleged offended party has no cause of action or relief. The fault or negligence of the defendant, therefore, is inextricably intertwined with the claim for damages, and there can be no action based on quasi-delict without a claim for damages.

Therefore, the subject matter of actions for damages based on quasi-delict is capable of pecuniary estimation.

Despite the Court’s concurrence in petitioner’s claim that actions for damages based on quasi-delict are actions that are capable of pecuniary estimation, we find that the total amount of damages claimed by the private respondent nevertheless still exceeds the jurisdictional limit of P400,000.00 and remains under the jurisdiction of the RTC.

The distinction petitioner made between damages arising directly from injuries in a quasi-delict and those arising from a refusal to admit liability for a quasi-delict is more apparent than real, as the damages sought by respondent originate from the same cause of action: the quasi-delict. The fault or negligence of the employee and the juris tantum presumption of negligence of his employer in his selection and supervision are the seeds of the damages claimed, without distinction.

Even assuming, for the sake of argument, that the claims for moral and exemplary damages arose from a cause of action other than the quasi-delict, their inclusion in the computation of damages for jurisdictional purposes is still proper. All claims for damages should be considered in determining the jurisdiction of the court regardless of whether they arose from a single cause of action or several causes of action. Rule 2, Section 5, of the Rules of Court allows a party to assert as many causes of action as he may have against the opposing party. Subsection (d) of said section provides that where the claims in all such joined causes of action are principally for recovery of money, the aggregate amount claimed shall be the test of jurisdiction.

Hence, whether or not the different claims for damages are based on a single cause of action or different causes of action, it is the total amount thereof which shall govern. Jurisdiction in the case at bar remains with the RTC, considering that the total amount claimed, inclusive of the moral and exemplary damages claimed, is P490,000.00.

In sum, actions for damages based on quasi-delicts are actions that are capable of pecuniary estimation. As such, they fall within the jurisdiction of either the RTC or the municipal courts, depending on the amount of damages claimed. In this case, the amount of damages claimed is within the jurisdiction of the RTC, since it is the claim for all kinds of damages that is the basis of determining the jurisdiction of courts, whether the claims for damages arise from the same or from different causes of action.

DISPOSITIVE:

WHEREFORE, the petition for review on certiorari is hereby DENIED for lack of merit. The Decision and Resolution of the Court of Appeals dated 28 October 2004 and 26 January 2005, respectively, are AFFIRMED insofar as they held that the Regional Trial Court has jurisdiction. No costs. SO ORDERED.