22) SANTE v.
CLARAVALL the totality of claim rule used for determining which court had
Doctrine:
It is settled that jurisdiction is conferred by law based on the facts alleged in
the complaint since the latter comprises a concise statement of ultimate facts
constituting plaintiffs cause of action.
FACTS:
Respondent Vita Kalashian filed before RTC Baguio a complaint for damages
against petitioners Irene and Reynaldo Sante.
Vita alleged that:
while she was inside the Police Station in, Irene asked her how
many rounds of sex she had with her boss, Bert (Vitas friend and
body guard who is a suspect of killing petitoners close relative), and
cursed her in the presence of other persons and police officers
Petitioners Sante went around the area telling people that she is
protecting and cuddling the suspects in the aforesaid killing
Petitioners Sante filed a MTD on the ground that it was the Municipal Trial
Court in Cities and not RTC of Baguio that had jurisdiction over the case
arguing that the amount of claim for moral damages was not more than
the jurisdictional amount of P300k, because the claim for exemplary
damages should be excluded in computing the total claim
The trial court DENIED the MTD and held that the total claim of respondent
Vita amounted to P420k which was above the jurisdictional amount for
MTCCs outside Metro Manila.
Petitioners Sante, after their MR was dismissed, filed a Petition for Certiorari
and Prohibition (FIRST) before CA.
Meanwhile, Vita and her husband filed an Amended Complaint increasing the
claim for moral damages from P300k to P1M.
Petitioners Sante filed a MTD DENIED
Petitioners Sante again filed a Petition for Certiorari and Prohibition
(SECOND) before CA claiming that the trial court committed grave abuse of
discretion in allowing the amendment of the complaint to increase amount of
damages
The CA GRANTED the FIRST petition for certiorari and prohibition, annulling
the orders to pay damages for lack of jurisdiction held that:
the case clearly falls under the jurisdiction of MTCC since Vita was
seeking to recover P300k for moral damages
jurisdiction could not be applied to the case because Vitas claim for
exemplary damages was not a separate and distinct cause of action
from her claim of moral damages, but merely incidental
The CA then AFFIRMED RTCs decision in denying the MTD, in the
SECOND petition filed by petitioners Sante held that:
the total amount demanded in the complaint constitutes the basis of
jurisdiction and did not find merit in petitioners Santes argument that
the claims for exemplary damages and attys fees are mere
incidental and should not be included in total claim
Vita can amend her complaint in increasing amount of damages on
the ground that the trial court has jurisdiction over the original
complaint
ISSUE: WON the RTC acquired jurisdiction over the case- YES
RULING:
-Administrative Circular No. 09-94: where the claim of damages is the main
cause of action, or one of the causes of action, the amount of such claim
shall be considered in determining the jurisdiction of the court
-In the present case, the complaint filed by Vita is for the recovery of
damages for alleged malicious acts of petitioners Sante sought the award
of moral and exemplary damages, attys fees, and litigation expenses for the
alleged shame and injury suffered by Vita
-It is settled that jurisdiction is conferred by law based on the facts alleged in
the complaint since the latter comprises a concise statement of ultimate facts
constituting plaintiffs cause of action
-Clearly, based on the allegations of Vitas complaint, the main action is for
damages hence, other forms of damages being claimed by respondent
(exemplary, attys fees, litigation expense) are not merely incidental to or
consequence of main action but constitute primary relief prayed for in the
complaint
-Considering that the total amount for damages claimed is P420k, the CA
was correct in ruling that RTC had jurisdiction over the case
WHEREFORE, petition is DENIED.
Winner: Respondent Vita Kalashian