July 26, 2017 | Author: Jf Maneja | Category: Laches (Equity), Damages, Jurisdiction, Certiorari, Writ
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Mangaliag v. Pastoral Facts: Respondent Serquina filed a complaint for damages with the RTC against petitioners Mangaliag and Solano. This complaint alleges that the Serquina and his co-passengers sustained serious injuries and permanent deformities from the collision of their tricycle with the petitioners’ dump truck and the gross negligence, carelessness and imprudence of the petitioners in driving the dump truck. Respondents seek damages in the form of medical expenses amounting to P71,392.00. Respondents also claim P500,000.00 by way of moral damages, as a further result of his hospitalization, lost income of P25,000.00 or the nominal damages, and attorney’s fees. Petitioners filed their answer with counterclaim. After pre-trial conference, trial on the merits ensued. After the respondent rested his case, petitioners testified in their defense. Subsequently, petitioners filed a motion to dismiss on the ground of lack of jurisdiction over the subject matter. They alleged that since the principal amount prayed for, in the amount of P71,392.00, falls within the jurisdiction of MTC. Petitioners maintain that the court’s jurisdiction should be based exclusively on the amount of actual damages, excluding therefrom the amounts claimed as moral, exemplary, nominal damages and attorney’s fee, etc. The respondent opposed the motion saying that since the claim for damages is the main action, the totality of the damages sought to be recovered should be considered in determining jurisdiction. He relied on Administrative Circular No. 09-94 which provides that “in cases where the claim for damages is the main cause of action. . . the amount of such claim shall be considered in determining the jurisdiction of the court” Also, the petitioners’ defense of lack of jurisdiction has already been barred by estoppel and laches. He contends that after actively taking part in the trial proceedings and presenting a witness to seek exoneration, it would be unfair and legally improper for petitioners to seek the dismissal of the case. RTC ruled in favor of respondent. Petitioners filed an MR which was denied. Subsequently, they filed a petition for certiorari with the SC. Issues: (1) Whether petitioners are barred from raising the defense of the RTC’s lack of jurisdiction? NO (2) Whether it is the amount of P71,392.00 as medical expenses, excluding moral, nominal damages and attorney’s fees, which determines jurisdiction, hence it is MTC which has jurisdiction? NO Ruling: (1) On the matter of estoppel and laches: In the present case, no judgment has yet been rendered by the RTC. As a matter of fact, as soon as the petitioners discovered the alleged jurisdictional defect, they did not fail or neglect to file the appropriate motion to dismiss. Hence, finding the pivotal element of laches to be absent, the Sibonghanoy doctrine does not control the present controversy. What happened in the Sibonghanoy, the party invoking lack of jurisdiction did so only after fifteen years and at a stage when the proceedings had already been elevated to the CA. Sibonghanoy is an exceptional case because of the presence of laches. But in this case, there is no laches. Thus, the general rule that the question of jurisdiction of a court may be raised at any stage of the proceedings must apply. Petitioners are not estopped from questioning the jurisdiction of the RTC. (2) On the issue which of the amounts is determinative of jurisdiction: The well-entrenched principle is that the jurisdiction of the court over the subject matter of the action is determined by the material allegations of the complaint and the law, irrespective of whether or not the plaintiff is entitled to recover all or some of the claims or reliefs sought therein. In the present case, the allegations in the complaint plainly show that private respondent seeks to recover not only his medical expenses, lost income but also damages for physical suffering and mental anguish due to permanent facial deformity from injuries sustained in the vehicular accident. Viewed as an action for quasi-delict, the present case falls squarely within the purview of Article 2219 (2), which provides for the payment of moral damages in cases of quasidelict causing physical injuries. Private respondent’s claim for moral damages of P500,000.00 cannot be considered as merely incidental to or a consequence of the claim for actual damages. It is a separate and distinct cause of action or an independent actionable tort. It springs from the right of a person to the physical integrity of his or her body,

and if that integrity is violated, damages are due and assessable. Hence, the demand for moral damages must be considered as a separate cause of action, independent of the claim for actual damages and must be included in determining the jurisdictional amount. If the rule were otherwise, i.e., the court’s jurisdiction in a case of quasi-delict causing physical injuries would only be based on the claim for actual damages and the complaint is filed in the MTC, it can only award moral damages in an amount within its jurisdictional limitations, a situation not intended by the framers of the law. (3) (Not really an issue raised by the respondent himself, but was nonetheless discussed by the SC) On the issue whether a direct recourse by petition for certiorari to the SC from the order of RTC: Generally a direct recourse to this Court is highly improper, for it violates the established policy of strict observance of the judicial hierarchy of courts. Although this Court, the RTCs and the CA have concurrent jurisdiction to issue writs of certiorari, prohibition, mandamus, quo warranto, habeas corpus and injunction, such concurrence does not give the petitioner unrestricted freedom of choice of court forum. This Court is a court of last resort, and must so remain if it is to satisfactorily perform the functions assigned to it by the Constitution and immemorial tradition. Thus, this Court, as a rule, will not entertain direct resort to it unless the redress desired cannot be obtained in the appropriate courts, and exceptional and compelling circumstances, such as cases of national interest and of serious implications, justify the availment of the extraordinary remedy of writ of certiorari, calling for the exercise of its primary jurisdiction. Be that as it may, the judicial hierarchy of courts is not an iron-clad rule. It generally applies to cases involving warring factual allegations. For this reason, litigants are required to repair to the trial courts at the first instance to determine the truth or falsity of these contending allegations on the basis of the evidence of the parties. Cases which depend on disputed facts for decision cannot be brought immediately before appellate courts as they are not triers of facts. Therefore, a strict application of the rule of hierarchy of courts is not necessary when the cases brought before the appellate courts do not involve factual but legal questions. In the present case, petitioners submit a pure question of law involving the interpretation and application of paragraph 2 of Administrative Circular No. 09-94. This legal question and in order to avoid further delay are compelling enough reasons to allow petitioners’ invocation of this Court’s jurisdiction in the first instance. (Maybe it is important to note that the petition for certiorari was filed from the denial of the RTC of the petitioners’ motion to dismiss. There is no final adjudication yet as to the complaint for damages.)

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