Russel vs. Vestil, 304 SCRA 738; GR No.
119347, March 17, 1999 whether jurisdiction is in the municipal courts or in the courts of first instance would
(Civil Procedures – Jurisdiction; Civil actions in which the subject of the
litigation is incapable of pecuniary estimation)
Facts: Petitioners discovered a public document, which is a declaration of heirs and
deed of confirmation of a previous oral agreement, of partition, affecting the land
executed by and among the respondents whereby respondents divided the property
among themselves to the exclusion of petitioners who are entitled thereto as legal
heirs also.
Petitioners filed a complaint, denominated “DECLARATION OF NULLITY AND
PARTITION” against defendants with the RTC claiming that the document was
false and perjurious as the private respondents were not the only heirs and that no
oral partition of the property whatsoever had been made between the heirs. The
complaint prayed that the document be declared null and void and an order be issued
to partition the land among all the heirs.
Private respondents filed a Motion to Dismiss the complaint on the ground of lack of
jurisdiction over the nature of the case as the total assessed value of the subject land
is P5,000.00 which under section 33 (3) of Batas Pambansa Blg. 129, as amended by
R.A. No. 7691, falls within the exclusive jurisdiction of the MTC.
Petitioners filed an Opposition to the Motion to Dismiss saying that the RTC has
jurisdiction over the case since the action is one which is incapable of pecuniary
estimation within the contemplation of Section 19(l) of B.P. 129, as amended.
Issue: WON the RTC has jurisdiction over the nature of the civil case.
Held: Yes. The complaint filed before the Regional Trial Court is one incapable of
pecuniary estimation and therefore within the jurisdiction of said court.
In Singsong vs. Isabela Sawmill, the Supreme Court ruled 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
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, this Court has
considered such actions as cases where the subject of the litigation may not be
estimated in terms of money, and are cognizable exclusively by courts of first
instance (now Regional Trial Courts).
The main purpose of petitioners in filing the complaint is to declare null and void the
document in question. While the complaint also prays for the partition of the
property, this is just incidental to the main action, which is the declaration of nullity
of the document above-described. 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
is entitled to all or some of the claims asserted therein.
Villena vs. Payoyo Case Digest
In determining the jurisdiction of an action whose subject is incapable 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 the jurisdiction of the court depends
on the amount of the claim. But, where the primary 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, such are actions whose subjects are
incapable of pecuniary estimation, hence cognizable by the RTCs.
Facts: Payoyo and Novaline, Inc., through its president, Villena, entered into a
contract for the delivery and installation of kitchen cabinets in Payoyo's residence.
The cabinets were to be delivered within 90 days from downpayment of 50% of the
purchase price. Payoyo paid the downpayment. Another contract was entered into for
the delivery of home appliances and Villena also paid the 50% downpayment.
Despite demand, Villena failed to install the kitchen cabinets and deliver the
appliances.
Payoyo filed a complaint for recovery of a sum of money and damages against Villena.
Villena posits that the RTC has no jurisdiction over the complaint since it is mainly for
recovery of a sum of money in the amount of P184,821.50 which is below the
jurisdictional amount set for RTCs.
Payoyo, on the other hand, contends that the RTC has jurisdiction over the complaint
as the allegations therein show that it is actually a case for rescission of the contracts.
The recovery of a sum of money is merely a necessary consequence of the
cancellation of the contracts.
Issue:
Whether or not the RTC has jurisdiction over the case.
Held: Yes. In determining the jurisdiction of an action whose subject is incapable 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 the jurisdiction of the court depends
on the amount of the claim. But, where the primary 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, such are actions whose subjects are
incapable of pecuniary estimation, hence cognizable by the RTCs.
Verily, what determines the nature of the action and which court has jurisdiction over
it are the allegations of the complaint and the character of the relief sought.
The complaint, albeit entitled as one for collection of a sum of money with damages,
is one incapable of pecuniary estimation; thus, one within the RTC's jurisdiction. The
allegations therein show that it is actually for breach of contract. A case for breach
of contract is a cause of action either for specific performance or rescission of
contracts. An action for rescission of contract, as a counterpart of an action for
specific performance, is incapable of pecuniary estimation, and therefore falls under
the jurisdiction of the RTC. The averments in the complaint show that Payoyo
sought the cancellation of the contracts and refund of the downpayments since
Villena failed to comply with the obligation to deliver the appliances and install the
kitchen cabinets subject of the contracts. While the respondent prayed for the refund,
this is just incidental to the main action, which is the rescission or cancellation of the
contracts.
CASE DIGEST : UNGRIA VS CA
CEFERINA DE UNGRIA [DECEASED], SUBSTITUTED BY HER HEIRS, REPRESENTED
BY LOLITA UNGRIA SAN JUAN-JAVIER, AND RHODORA R. PELOMIDA AS THEIR
ATTORNEY-IN-FACT, PETITIONER, VS. THE HONORABLE COURT OF APPEALS, THE
HONORABLE REGIONAL TRIAL COURT OF GENERAL SANTOS CITY, BRANCH 35,
ROSARIO DIDELES VDA. DE CASTOR, NEPTHALIE CASTOR ITUCAS, FEROLYN
CASTOR FACURIB, RACHEL DE CASTOR, LEA CASTOR DOLLOLOSA, AND ROSALIE
CASTOR BENEDICTO, RESPONDENTS
FACTS : Benedicto, filed with the Regional Trial Court (RTC) of General Santos City a
Complaint[3] for ownership, possession and damages, and alternative causes of
action either to declare two documents as patent nullities, and/or for recovery of
Rosario's conjugal share with damages or redemption of the subject land against
petitioner Ceferina de Ungria. The documents they sought to annul are (1) the Deed
of Transfer of Rights and Interest including Improvements thereon dated October 3,
1960 allegedly executed by Fernando in favor of Eugenio de Ungria, petitioner's
father; and (2) the Affidavit of Relinquishment dated November 23, 1960 executed
by Eugenio in favor of petitioner. Petitioner Ceferina filed a Motion to
DismissPetitioner also filed an Addendum to the Motion to Dismiss[5] raising the
following additional grounds: (1) plaintiffs have no legal capacity to sue; and (2) the
court has no jurisdiction over the case for failure of plaintiffs to pay the filing fee in full.
On November 19, 1999, the RTC issued an Order[6] denying the motion to dismiss.
Petitioner Ceferina filed a Motion for Reconsideration,[8] which the RTC denied in an
Order[9] dated February 4, 2000. Petitioner filed an Omnibus Motion[10] asking the
RTC to resolve the issues of (1) whether or not the complaint should be dismissed or
expunged from the records pursuant to Supreme Court (SC) Circular No. 7; (2)
reconsidering the findings contained in the Order dated February 4, 2000; and (3)
holding in abeyance the submission of the answer to the complaint. In an Order dated
May 31, 2000, the RTC again denied petitioner's motion for reconsideration.
Petitioner filed with the CA a petition for certiorari and prohibition with prayer for the
issuance of a temporary restraining order and/or writ of preliminary injunction.
Petitioner sought the nullification of the Order dated November 19, 1999 and the
subsequent orders issued by the RTC thereto for having been issued with grave
abuse of discretion amounting to lack or excess of jurisdiction. Respondents filed
their Comment thereto.
In a Decision dated May 26, 2004, the CA dismissed the petition Petitioner filed a
Motion for Reconsideration, which the CA denied in a Resolution dated September 17,
2004. The CA ruled, among others, that the defenses of acquisitive prescription and
laches were likewise unavailing. Hence, this petition for review on certiorari
admitted, or shall otherwise be expunged from the record; and that the Court
acquires jurisdiction over any case only upon the payment of the prescribed docket
fee
However, in Sun Insurance Office, Ltd. v. Asuncion,[30] we laid down the following
guidelines in the payment of docket fees, to wit:

ISSUE : WON APPEALS ERRED IN NOT FINDING THAT RESPONDENT TRIAL 1. It is not simply the filing of the complaint or appropriate initiatory pleading, but
COURT COMMITTED GRAVE ABUSE OF DISCRETION IN DENYING the payment of the prescribed docket fee, that vests a trial court with jurisdiction
PETITIONER'S MOTION TO DISMISS DESPITE RESPONDENTS' over the subject matter or nature of the action. Where the filing of the initiatory
NON-PAYMENT OF THE CORRECT DOCKET FEES pleading is not accompanied by payment of the docket fee, the court may allow
payment of the fee within a reasonable time but in no case beyond the applicable
prescriptive or reglementary period.
HELD : we find it necessary to discuss the issue of jurisdiction over the subject
2. The same rule applies to permissive counterclaims, third-party claims and
matter of this case. Respondents' complaint was filed in 1999, at the time Batas
similar pleadings, which shall not be considered filed until and unless the filing fee
Pambansa Blg. (BP) 129, the Judiciary Reorganization Act of 1980, was already
prescribed therefor is paid. The court may also allow payment of said fee within a
amended by Republic Act (RA) No. 7691, An Act Expanding the Jurisdiction of the
reasonable time but also in no case beyond its applicable prescriptive or
Metropolitan Trial Courts, Municipal Trial Courts, and Municipal Circuit Trial Courts, reglementary period.
amending for the purpose BP Blg. 129. It would appear that the first cause of action
involves the issue of recovery of possession and interest of the parties over the 3. Where the trial court acquires jurisdiction over a claim by the filing of the
subject land which is a real action. Respondents alleged that the assessed value of appropriate pleading and payment of the prescribed filing fee but, subsequently, the
the subject land was P12,780.00 based on Tax Declaration No. 15272. Thus, since it judgment awards a claim not specified in the pleading, or if specified the same has
is a real action with an assessed value of less than P20,000.00, the case would fall been left for determination by the court, the additional filing fee therefor shall
under the jurisdiction of the MTC as provided under the above-quoted Section 33 (3) constitute a lien on the judgment. It shall be the responsibility of the Clerk of Court
of BP 129, as amended. It is a settled rule in this jurisdiction that when an action is or his duly-authorized deputy to enforce said lien and assess and collect the
filed in court, the complaint must be accompanied by the payment of the requisite additional fee.
docket and filing fees.[23] It is not simply the filing of the complaint or appropriate
It is a well-entrenched rule in this jurisdiction that no title to registered land in
initiatory pleading, but the payment of the prescribed docket fee, that vests a trial
derogation of the rights of the registered owner shall be acquired by prescription or
court with jurisdiction over the subject matter or nature of the action. Since we find
adverse possession.[33] Prescription is unavailing not only against the registered
that the case involved the annulment of contract which is not susceptible of pecuniary
owner but also against his hereditary successors.[34] In this case, the parcel of land
estimation, thus, falling within the jurisdiction of the RTC, the docket fees should not
subject of this case is a titled property, i.e., titled in the name of the late Fernando
be based on the assessed value of the subject land as claimed by petitioner in their
Castor, married to Rosario Dideles
memorandum, but should be based on Section 7(b)(1) of Rule 141. A perusal of the
entries in the Legal Fees Form attached to the records would reflect that the amount
of P400.00 was paid to the Clerk of Court, together with the other fees, as assessed
by the Clerk of Court. Thus, upon respondents' proof of payment of the assessed fees,
the RTC has properly acquired jurisdiction over the complaint. Jurisdiction once
acquired is never lost, it continues until the case is terminated

SC Circular No. 7 was brought about by our ruling in Manchester Development

Corporation v. Court of Appeals,[29] where we held that a pleading which does not
specify in the prayer the amount of damages being asked for shall not be accepted or

SURVIVING HEIRS OF ALFREDO R. BAUTISTA VS. LINDO
G.R. No. 208232, March 10, 2014
Facts:
Alfredo R. Bautista (Bautista), petitioner’s predecessor, inherited in 1983 a
free-patent land located in Davao Oriental and covered by OCT No. (1572) P-6144.A
few years later, he subdivided the property and sold it to several vendees, herein
respondents, via a notarized deed of absolute sale dated May 30, 1991. Two months
later, OCT No.(1572) P-6144 was canceled and Transfer Certificates of Title (TCTs)
were issued in favor of the vendees.
On August 1994, Bautista filed a complaint for repurchase against respondents
before the RTC, anchoring his cause of action on Section 119 of Commonwealth Act
No. (CA) 141, otherwise known as the “Public Land Act,” which reads:
“SECTION 119. Every conveyance of land acquired under the free patent or
homestead provisions, when proper, shall be subject to repurchase by the applicant,
his widow, or legal heirs, within a period of five years from the date of the
conveyance.”
During the pendency of the action, Bautista died and was substituted by petitioner,
Efipania. Respondents, Sps. Lindo entered into a compromise agreement with
petitioners, whereby they agree to cede to Epifania 3,230 sq.m..portion of the
property as well as to waive, abandon, surrender, and withdraw all claims and
counterclaims against each other. RTC approve the compromise agreement on
January 2011.
Other respondents, filed a Motion to Dismissed on February 2013 alleging lack of
jurisdiction of the RTC on the ground that the complaint failed to state the value of
the property sought to be recovered and alleges that the total value of the properties
in issue is only P16,500 pesos. RTC ruled in favor of the respondent dismissing the
case.
Issue:
Whether or not the RTC erred in granting the motion for the dismissal of the case on
the ground of lack of jurisdiction over the subject matter.
Ratio:
Yes. Jurisdiction of courts is granted by the Constitution and pertinent laws.
Jurisdiction of RTCs, as may be relevant to the instant petition, is provided in Sec. 19
of BP 129.
Issue:
Whether the action filed by petitioners is one involving title to or possession of real
property or any interest therein or one incapable of pecuniary estimation.
Ratio:
The Court rules that the complaint to redeem a land subject of a free patent is a civil
action incapable of pecuniary estimation.
It is a well-settled rule that jurisdiction of the court is determined by the allegations
in the complaint and the character of the relief sought. In this regard, the Court, in
Russell v. Vestil, wrote 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
RTCs would depend on the amount of the claim." But 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, this Court has
considered such actions as cases where the subject of the litigation may not be
estimated in terms of money, and, hence, are incapable of pecuniary estimation.
Decision:
WHEREFORE, premises considered, the instant petition is hereby GRANTED. The April
25, 2013 and July 3, 2013 Orders of the Regional Trial Court in Civil Case No.
(1798)-021 are hereby REVERSED and SET ASIDE.
The Regional Trial Court, Branch 32 in Lupon, Davao Oriental is ORDERED to proceed
with dispatch in resolving Civil Case No. (1798)-021.
Hilario v. Salvador, G.R. No. 160384 (April 29, 2005) Case Digest
Ownership > Ownership in General > Recovery of Possession and/or Ownership >
Actions Available to Owner > Recovery of Real Property > Accion Publiciana and
Accion Reinvindicatoria
Facts:
Hilario filed a complaint with the RTC against Salvador alleging that they were the
co-owners of the parcel of land where Salvador constructed his house without their
knowledge and refused to vacate despite their demands.
Salvodor filed a motion to dismiss the complaint on the ground of lack of
jurisdiction. He contended that the complaint did not state the assessed value of the
property, which determines the jurisdiction of the court.
Hilario maintained that the RTC had jurisdiction since their action was an accion
reinvindicatoria, an action incapable of pecuniary estimation; thus, regardless of the
assessed value of the subject property, exclusive jurisdiction fell within the said court.
Also, in their opposition to Salvador's motion to dismiss, they mentioned the increase
in the assessed value of the land in the amount of P3.5 million. Moreover, they
maintained that their action was also one for damages exceeding P20,000.00, over
which the RTC had exclusive jurisdiction.
Issue:
Whether or not the action filed by Hilario was an accion reinvindicatoria.
Whether or not the RTC had jurisdiction over the complaint filed by Hilario.
Held:
The action filed by Hilario did not involve a claim of ownership over the property.
They prayed that Salvador vacate the property and restore possession to
them. Hence, it was an accion publiciana, or one for the recovery of possession of
the real property. It was not an aaccion reinvindicatoria or a suit for the recovery of
possession over the real property as owner.
The nature of the action and which court has original and exclusive jurisdiction is
determined by the material allegations of the complaint, the type of relief prayed for
by the plaintiff and the law in effect when the action is filed, irrespective of whether
the plaintiffs are entitled to some or all of the claims asserted therein.
The complaint did not contain an allegation stating the assessed value of the
property. Absent any allegation in the complaint of the assessed value of the
property, it could not thus be determined whether the RTC or the MTC had original
and exclusive jurisdiction over the action.
The law also explicitly excluded from the determination of the jurisdictional amount
the demand for interest, damages of whatever kind, attorneys fees, litigation
expenses, and costs.
Since the RTC had no jurisdiction over the action, all the proceedings therein,
including the decision of the RTC, were null and void.
San Pedro vs Asdala
593 SCRA 397
Facts:
Private respondents filed with the MeTC of Q.C. a complaint against petitioners
and Wood Crest Residents Assoc., Inc., for accion reivindicatoria, quieting of title and
damages, with prayer for preliminary injunction. Private respondents alleged that
subject property located in Batasan Hills, Quezon City, with an assessed value of
P32,100.00, was titled in the name of spouses Apolonio and Valeriana Dionisio; but
petitioners, with malice and evident bad faith, claimed that they were the owners of
a parcel of land that encompasses and covers subject property. Private respondents
had allegedly been prevented from entering, possessing and using subject property.
It was further alleged in the Complaint that petitioners' Transfer Certificate of Title
over their alleged property was spurious. Private respondents then prayed that they
be declared the sole and absolute owners of the subject property; that petitioners be
ordered to surrender possession of subject property to them; that petitioners and
Wood Crest and/or its members be ordered to pay actual and moral damages, and
attorney's fees.
Petitioners, filed a motion to dismiss on the ground that the Metc had no
jurisdiction, as the subject of litigation was incapable of pecuniary estimation.
The MeTC then issued an order denying the motion to dismiss, ruling
that, under Batas Pambansa (B.P.) Blg. 129, as amended, the MeTC had exclusive
original jurisdiction over actions involving title to or possession of real property of
small value. Their motion for reconsideration was also denied.
Petitioners filed a petition for certiorari with the RTC which was also dismissed.
Petitioners then filed with the CA another petition for certiorari. The CA dismissed
the petition holding that certiorari was not available to petitioners as they should
have availed themselves the remedy of appeal.
Issue:
Whether or not the RTC and the CA ruled correctly that the MeTV had jurisdiction
over private respondent’s complaint for accion reivindicatoria.
Held:
Yes they did.
To put the matter to rest, the Court reiterates the ruling in Heirs of Valeriano S.
Concha, Sr. v. Spouses Lumocso, to wit:
In a number of cases, we have held that actions for reconveyance of or for
cancellation of title to or to quiet title over real property are actions that fall under the
classification of cases that involve “title to, or possession of, real property, or any
interest therein.”
“Thus, under the old law, there was no substantial effect on jurisdiction whether
a case is one, the subject matter of which was incapable of pecuniary estimation,
under Section 19(1) of B.P. 129, or one involving title to property under Section
19(2). The distinction between the two classes became crucial with the amendment
introduced by R.A. No. 7691 in 1994, which expanded the exclusive original
jurisdiction of the first level courts to include "all civil actions which involve title to, or
possession of, real property, or any interest therein where the assessed value of the
property or interest therein does not exceed Twenty thousand pesos (P20,000.00) or,
in civil actions in Metro Manila, where such assessed value does not exceed Fifty
thousand pesos (P50,000.00) exclusive of interest, damages of whatever kind,
attorney's fees, litigation expenses and costs." Thus, under the present law, original MASLAG V MONZON
jurisdiction over cases the subject matter of which involves "title to, possession of,
real property or any interest therein" under Section 19(2) of B.P. 129 is divided FACTS: In 1998, petitioner filed a Complaint7 for reconveyance of real property with
between the first and second level courts, with the assessed value of the real declaration of nullity of original certificate of title (OCT) against respondents
property involved as the benchmark. This amendment was introduced to "unclog the Elizabeth Monzon, William Geston and the Registry of Deeds of La Trinidad, Benguet.
overloaded dockets of the RTCs which would result in the speedier administration of
After trial, the MTC found respondent Monzon guilty of fraud in obtaining an OCT over
justice."
petitioner’s property, that cause the respondent to appeal to the RTC of La Trinidad.
Clearly, the RTC and the CA ruled correctly that the MeTC had jurisdiction over
October 22, 2003, declaring the MTC without jurisdiction over petitioner’s cause of
private respondents' complaint for Accion Reivindicatoria.
action. Appeal from orders dismissing case without trial; lack of jurisdiction.

On May 4, 2004, Judge Diaz De Rivera issued a Resolution reversing the MTC
Decision. to turn over the possession of the 4,415 square meter land she presently
occupies to [Monzon]. This case is remanded to the court a quo for further
proceedings to determine whether [Maslag] is entitled to the remedies afforded by
law to a builder in good faith for the improvements she constructed thereon.

Petitioner filed a Notice of Appeal 15 from the RTC’s May 4, 2004 Resolution and
prayed that the MTC Decision be adopted.

Respondents moved to dismiss petitioner’s ordinary appeal for being the improper
remedy. They asserted that the proper mode of appeal is a Petition for Review under
Rule 42 because the RTC rendered its May 4, 2004 Resolution in its appellate
jurisdiction.

September 22, 2006, The CA dismissed petitioner’s appeal cited the earlier October
22, 2003 Order of the RTC declaring the MTC without jurisdiction over the case. A
perusal of the May 4, 2004 Resolution of the RTC, which is the subject matter of the
appeal, clearly reveals that it took cognizance of the MTC case in the exercise of its
appellate jurisdiction.

ISSUE: W o N the CA was correct in dismissing petitioner’s appeal.

HELD: YES, the CA is correct in affirming RTC decision.

Under the present state of the law, in cases involving title to real property, original
and exclusive jurisdiction belongs to either the RTC or the MTC, depending on the
assessed value of the subject property.28 Pertinent provisions of Batas Pambansa Blg.
(BP) 129,29 as amended by Republic Act (RA) No. 7691.
Regional Trial Courts shall exercise exclusive original jurisdiction:
(1) In all civil actions in which the subject of the litigation is incapable of
pecuniary estimation;
(2) In all civil actions which involve the title to, or possession of, real property,
or any interest therein, where the assessed value of the property involved
exceeds Twenty thousand pesos (P20,000.00) or for civil actions in Metro
Manila, where x x x the assessed value of the property exceeds Fifty thousand
pesos ([P]50,000.00) except actions for forcible entry into and unlawful
detainer of lands or buildings, original jurisdiction over which is conferred
upon Metropolitan Trial Courts, Municipal Trial Courts, and Municipal Circuit
Trial Courts;
Metropolitan Trial Courts, Municipal Trial Courts and Municipal Circuit Trial Courts in
Civil Cases. — Metropolitan Trial Courts, Municipal Trial Courts and Municipal Circuit
Trial Courts shall exercise:
(3) Exclusive original jurisdiction in all civil actions which involve title to, or
possession of, real property, or any interest therein where the assessed
value of the property or interest therein does not exceed Twenty thousand
pesos (P20,000.00) or, in civil actions in Metro Manila, where such assessed
value does not exceed Fifty thousand pesos (P50,000.00)
Judge Cabato, erred in applying Section 19(1) of BP 129 in determining which court
has jurisdiction over the case and in pronouncing that the MTC is divested of original
and exclusive jurisdiction.In the mistaken choice of their remedy, they can blame no
one but themselves.
Petition is denied for lack of merit.
Movers-Baseco Integrated Port Services, Inc. vs. Cyborg Leasing Corp.
Facts: Cyborg Leasing Corp filed before the MTC of Manila a case captioned "Damages
withprayer for a writ Replevin" against Conpac and Movers. It was alleged that pursuant toa lease
agreement, Cyborg had delivered one forklift to Conpac. The lease
agreementstipulated a monthly rental of P11,000.00 for the use of the equipment. Conpac
failedand refused to pay the stipulated rentals. Petitioner took control of the
operations of Conpac and seized all the cargoes and equipment in ludi g the subject
porklift.Petitioner ignored Cyborg's demand for the return to it of the equipment and the
formaldisclaimer of ownership made by Conpac. A Writ of Replevin was issued.Petitioner was
served with a copy of the summons and the latter filed a motion todismiss the case on the
ground of lack of jurisdiction on the part of the of MTC sincethe complaint had asked
for the actual market value of the equipment, actual damage,,exemplary damages
and atty's fees. MTC dismissed the complaint for lack of jurisdiction.Cyborg filed a
petition for certiorari and prohibition with preliminary injuction againstMTC Judge,
COnpac and Movers before the RTC f Manila. RTC granted Cyborg'sapplication for premininary
injunction. Petitiner assails the decision of RTC. Hence thispetition.Issue:
WON, MTC has jurisdiction over the complaint?
Held: NO MTC's jurisdiction over the action filed by Cyborg is the concern of thecase.
The jurisdiction of the court and the nature of the action must be determined by th
eaverments in the complaints and the character of the relief sought. The complaint filedby Cyborg
with the MTC prayed for the return of the Nissan Forklift to it as the owner orin the alternative for
the payment of 150T plus damages, amount of unpaid lease andatty's fees.It would be incorrect
to argue that the actual damages in the form of unpaid rentalswere just in incident of the
action for the return of the forklift considering that privaterespondent specifically sought
in the complaint not only seizure of the forklift frompetitioner Movers but also payment of
unpaid and outstanding rentals. MTC's dismissing the complaint was properly decreed,
Petition for review is granted
\ of the claims or reliefs sought therein. In the present case, the allegations in the
MANGALIAG vs. CATUBIG
G.R. No. 143951 October 25, 2005
474 SCRA 153
Facts:Private resp. Apolinario Serquina, Jr. filed before the RTC a complaint for
damages against petitioners Norma Mangaliag and Narciso Solano for failure to
exercise extraordinary diligence in the selection of her (truck driver) resulting to
serious injuries and permanent deformities of respondent and his co-passengers
therein. Petitioners filed a motion to dismiss on the ground of lack of jurisdiction over
the subject matter of the claim, alleging that the Municipal Trial Court has jurisdiction
over the case since the principal amount prayed for, in the amount of P71,392.00,
falls within its jurisdiction.
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.
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
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 quasi-delict 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, in clear consonance with
paragraph 2 of Administrative Circular No. 09-94.

Issue: In an action for recovery of damages, does the amount of actual damages
prayed for in the complaint provide the sole test for determining the court’s
jurisdiction, or is the total amount of all the damages claimed, regardless of kind and
nature, such as moral, exemplary, nominal damages, and attorney’s fees, etc., to be
computed collectively with the actual damages to determine what court – whether
the MTC or the RTC – has jurisdiction over the action?

Held:
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