Iniego vs Purganan

G. R. No. 166876 March 24, 2006

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 24 August 2002, private respondent filed a Motion to Declare defendant in Default allegedly for failure of the
latter to file his answer within the final extended period. 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, acting as presiding judge of the RTC, Branch
42, Manila, issued the assailed Omnibus Order denying the Motion to Dismiss of the petitioner and the Motion to
Declare Defendant in Default of the private respondent.

On 22 November 2004, petitioner moved for reconsideration, which was denied by the Court of Appeals on 26
January 2005. Hence, this present petition.

Petitioner claims that actions for damages based on quasi-delict are actions that are capable of pecuniary
estimation; hence, the jurisdiction in such cases falls upon either the municipal courts (the Municipal Trial Courts,
Metropolitan Trial Courts, Municipal Trial Courts In Cities, And Municipal Circuit Trial Courts), or the Regional Trial
Courts, depending on the value of the damages claimed.

Petitioner argues further that should this Court 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.

Issues:

Whether or not actions for damages based on quasi-delict are actions that are capable of pecuniary estimation,
and therefore would fall under the jurisdiction of the municipal courts if the claim does not exceed the
jurisdictional amount of P400,000.00 in Metro Manila.

Whether or not the moral and exemplary damages claimed by the private respondent should be excluded from the
computation of the above-mentioned jurisdictional amount because they arose from a cause of action other than
the negligent act of the defendant.

Held:
 I

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, and are therefore capable of
pecuniary estimation.

According to respondent Judge, what he referred to in his assailed Order as not capable of pecuniary estimation is
the cause of action, which is a quasi-delict, and not the amount of damage prayed for. From this, respondent Judge
concluded that since fault or negligence in quasi-delicts cannot be the subject of pecuniary estimation, the RTC has
jurisdiction. The Court of Appeals affirmed respondent Judge in this respect.

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. 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."

In Lapitan v. Scandia, Inc the court stated that 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.

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.

Fault or negligence, which the Court of Appeals claims is not capable of pecuniary estimation, 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.

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.

We therefore rule that the subject matter of actions for damages based on quasi-delict is capable of pecuniary
estimation.

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.

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.
Petitioner argues that in actions for damages based on quasi-delict, claims for damages arising from a different
cause of action (i.e., other than the fault or negligence of the defendant) should not be included in the
computation of the jurisdictional amount. According to petitioner, the moral and exemplary damages claimed by
the respondents in the case at bar are not direct and proximate consequences of the alleged negligent act. If the
claims for moral and exemplary damages are not included in the computation for purposes of determining
jurisdiction, only the claim for actual damages in the amount of P40,000.00 will be considered, and the MeTC will
have jurisdiction.

The court did not give credence to petitioner’s arguments. 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.

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.