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Sante vs Claraval Topic: Jurisdiction Nature: Petition for certiorari Facts: 1) In April 2004, private respondent Vita Kalashian

filed before RTC Baguio a complaint for damages against petitioners Irene Sante and Reynaldo Sante. Respondent alleged that while she was inside the Police Station in Pangasinan, and in the presence of other persons and police officers, Irene Sante uttered the words, How many rounds of sex did you have last night with your boss, Bert? You fuckin bitch! Bert refers to a friend of the respondent and one of her hired security guards in said station, and a suspect in the killing of petitioners close relative. Petitioners also allegedly went around Pangasinan telling people that she is protecting and cuddling the suspects in the aforesaid killing. Thus, respondent prayed for the following: Moral Damages Exemplary Damages Attorneys fees Litigation expenses 300,000 50, 000 50, 000 20, 000

2) Petitioners filed a motion to dismiss on the ground of jurisdiction. They claimed that the Municipal Trial Court in Cities instead of RTC Baguio should take cognizance. They argued that the amount of the claim for moral damages was not more than the jurisdictional amount of P300,000.00, because the claim for exemplary damages should be excluded in computing the total claim. 3) The trial court denied the motion to dismiss on the ground that the amount of demand P420,000 was above the jurisdictional amount for MTCCs outside Metro Manila. 4) Petitioners filed a petition for certiorari and prohibition with the CA. Meanwhile, respondent filed an amended complaint increasing the claim for moral damages to P1,000,000. Petitioners then filed a motion to dismiss which was denied. 5) Petitioners AGAIN filed a petition for certiorari and prohibition with the CA, raising that RTC Baguio committed grave abuse of discretion in allowing the amended complaint. CA ruled in favor of petitioners, stating that MTCC had jurisdiction because considering ONLY the demand for P300,000 moral damages. The CA held that the demand for exemplary damages was merely incidental. 6) Hence, this petition for certiorari. Issues: Whether RTC acquired jurisdiction of the case Whether RTC committed grave abuse of discretion in allowing the amended complaint Held: YES. RTC acquired jurisdiction. Hence, there was no grave abuse of discretion. Ratio Decidendi: PETITIONERS CONTENTION: The claim for moral damages, in the amount of P300,000.00 in the original complaint, is the main action. The exemplary damages being discretionary should not be included in the computation of the jurisdictional amount. Thus, RTC acted with grave abuse of discretion in allowing the amended complaint. RESPONDENTS CONTENTION: The nature of her complaint is for recovery of damages. As such, the totality of the claim for damages, including the exemplary damages as well as the other damages alleged and prayed in the complaint, such as attorneys fees and litigation expenses, should be included in determining jurisdiction. The exclusion of the term damages of whatever kind in determining the jurisdictional amount under B.P. Blg. 129 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. In the instant case, the complaint filed is for the recovery of damages for the acts of the petitioners. The complaint principally sought an award of moral and exemplary damages, as well as attorneys fees and litigation expenses, for the alleged shame and injury suffered by respondent. 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 plaintiffs causes of action. It is clear, based on the allegations of the complaint, that respondents main action is for damages. Hence, the other forms of damages being claimed by respondent, e.g., exemplary damages, attorneys 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. Considering that the total amount of damages claimed was P420,000.00, the Court of Appeals was correct in ruling that the RTC had jurisdiction over the case.

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