JURISDICTION OVER CASES WHERE THE CLAIM FOR DAMAGES IS THE MAIN CAUSE OF ACTION

In Irene Sante and Reynaldo Sante vs. Hon. Edilberto Claraval,  the Supreme Court clarified that jurisdiction is conferred by law based on the facts alleged in the complaint since the latter comprises a concise statement of the ultimate facts constituting the plaintiff’s causes of action (Nocum v. Tan, G.R. No. 145022, September 23, 2005, 470 SCRA 639, 644-645).  Since it is clear, based on the allegations of the complaint therein that respondent’s main action is for damages, the other forms of damages being claimed by respondent, e.g., exemplary damages, attorney’s fees and litigation expenses, are not merely incidental to or consequences of the main action but constitute the primary relief prayed for in the complaint.  

The exclusion of the term “damages of whatever kind” in determining the jurisdictional amount under Section 19 (8) and Section 33 (1) of B.P. Blg. 129, as amended by R.A. No. 7691, applies to cases where the damages are merely incidental to or a consequence of the main cause of action.   However, in cases where the claim for 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 (Administrative Circular No. 09-94).

This is the tenor of the ruling of the Supreme Court in Mendoza v. Soriano, (G.R. No. 164012, June 8, 2007, 524 SCRA 260, 266-267), where it held that in cases where the claim for 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 said case, the respondent’s claim of P929,000.06 in damages and P25,000 attorney’s fees plus P500 per court appearance was held to represent the monetary equivalent for compensation of the alleged injury.  The Court therein held that the total amount of monetary claims including the claims for damages was the basis to determine the jurisdictional amount. x x x x x

Similarly, in Iniego v. Purganan, G.R. No. 166876, March 24, 2006, 485 SCRA 394, 4020, the Supreme Court held that “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.  x x x x

Considering therefore that the total amount of damages being claimed by respondent herein (moral damages in the amount of P300,000.00; P50,000.00 as exemplary damages; P50,000.00 attorney’s fees; P20,000.00 litigation expenses; and costs of suit) for the alleged shame and injury suffered by reason of petitioners’ utterance while they were at a police station in Pangasinan was P420,000.00, the case falls within the jurisdiction of the Regional Trial Court (RTC) of Pangasinan. (IRENE SANTE AND REYNALDOSANTE vs. HON. EDILBERTO T. CLARAVALL, G.R. No. 173915, February 22, 2010, VILLARAMA, JR., J.).