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Radio Communications vs. CA
Radio Communications vs. CA
*
G.R. No. 136109. August 1, 2002.
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SUPREME COURT REPORTS ANNOTATED VOLUME 386 12/1/19, 12:12 PM
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* FIRST DIVISION.
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YNARES-SANTIAGO, J.:
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SUPREME COURT REPORTS ANNOTATED VOLUME 386 12/1/19, 12:12 PM
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6
SO ORDERED.‰
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6 Ibid., p. 53.
7 Under Section 5 of Republic Act No. 7691, which took effect in 1994, and
Circular 21-99, the jurisdictional amount for Regional Trial Court should be
adjusted as follows: Five years after the effectivity of Republic Act No. 7691,
the amount exceeds Two Hundred Thousand Pesos (P200,000.00); and five
years thereafter, the amount exceeds Three Hundred Thousand Pesos
(P300,000.00). However, in the case of Metro Manila, the above-mentioned
jurisdictional amounts shall be adjusted after five years from the effectivity of
Republic Act No. 7691 such that the amount exceeds Four Hundred Thousand
Pesos (P400,000.00) [Feria, Noche, Civil Procedure Annotated, 2001, Vol. 1, pp.
163-164.]
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SUPREME COURT REPORTS ANNOTATED VOLUME 386 12/1/19, 12:12 PM
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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.
xxx xxx x x x.
8
In Russell, et al. v. Vestil, et al., the Court held that in
determining whether an action is one the subject matter of
which is not capable of pecuniary estimation, the nature of
the principal action or remedy sought must first be
ascertained. If it is primarily for the recovery of a sum of
money, the claim is considered capable of pecuniary
estimation, and jurisdiction over the action will 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, the action is one
where the subject of the litigation may not be estimated in
terms of money, which is cognizable exclusively by Regional
Trial Courts.
It is axiomatic that jurisdiction over the subject matter
of a case is conferred by law and is determined by the
allegations in the complaint and the character of the relief
sought, irrespective of whether the plaintiff
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is entitled to
all or some of the claims asserted therein.
In the case at bar, the allegations in the complaint
plainly show that private respondentÊs cause of action is
breach of contract. The pertinent portion of the complaint
recites:
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8 304 SCRA 738, 744 [1999], citing Singson v. Isabela Sawmill, 88 SCRA 623
[1979]; Raymundo v. Court of Appeals, 213 SCRA 457 [1992].
9 Russel, supra, citing Garcia v. Court of Appeals, 273 SCRA 239 [1997];
Cañiza v. Court of Appeals, 268 SCRA 640 [1997].
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SUPREME COURT REPORTS ANNOTATED VOLUME 386 12/1/19, 12:12 PM
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SUPREME COURT REPORTS ANNOTATED VOLUME 386 12/1/19, 12:12 PM
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therefore
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fall under the jurisdiction of the Regional Trial
Court. Here, the averments in the complaint reveal that
the suit filed by private respondent was primarily one for
specific performance as it was aimed to enforce their three-
year lease contract which would incidentally entitle him to
monetary awards if the court should find that the subject
contract of lease was breached. As alleged therein,
petitionerÊs failure to pay rentals due for the period from
January to March 1997, constituted a violation of their
contract which had the effect of accelerating the payment of
monthly rentals for the years 1997 and 1998. The same
complaint likewise implied a premature and unilateral
termination of the term of the lease with the closure of and
removal 14all communication equipment in the leased
premises. Under the circumstances, the court has to
scrutinize the facts and the applicable laws in order to
determine whether there was indeed a violation of their
lease agreement that would justify the award of rentals
and damages. The prayer, therefore, for the payment of
unpaid rentals in the amount of P84,000.00 plus damages
consequent to the breach is merely incidental to the main
action for specific performance.
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Similarly, in
ManufacturerÊs DistributorÊs Inc., the Court explained·
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SUPREME COURT REPORTS ANNOTATED VOLUME 386 12/1/19, 12:12 PM
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