Case Digests

C
of Micah Pogi (CivPro: Jurisdiction) 2014

Sante v. Claravall
G.R. No. 173915
22 February 2010
Vilarama, J.:

Facts:

Vita Kalashian filed a complaint for damages with the RTC against Irene Sante after the
latter uttered defamatory statements against her. The claims made were for moral
damages amounting to P300,000.00, exemplary damages worth P50,000.00, attorney’s
fees in the amount of P50,000.00, and litigation expenses totaling P20,000.00, for an
aggregate sum of P420,000.00.

Sante moved to have the case dismissed alleging lack of jurisdiction on the part of the
RTC. She contends that since the claim for moral damages is the main action in the
complaint, then the jurisdiction over the case belongs to the MTC as it does not exceed
P300,000.00. On the other hand, Kalashian avers that since her complaint is for
recovery of damages, 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
attorney’s fees and litigation expenses, should be included in determining jurisdiction.
The total claim being P420,000.00, the RTC has jurisdiction over the complaint.

Issue:

WON the RTC has jurisdiction over the case.

Held:

YES. It is true that B.P. 129 provides that in determining the RTCs jurisdiction the
amount of damages claimed, attorney’s fees, litigation expenses, etc., should be
excluded in the value of the demand. However, this only applies when the claims for
such damages and other charges are merely incidental to the main cause of action and
is not applicable when the main purpose of the action is to recover damages (S.C.
Administrative Circular No. 09-94).

In the instant case, the complaint principally sought an award of moral and exemplary
damages, as well as attorney’s fees and litigation expenses, for the alleged shame and
injury suffered by respondent by reason of Sante’s utterances. It is clear, based on the
allegations of the complaint that Kalashian’s main action is for damages. Hence, the
other forms of damages being claimed by respondent, e.g., exemplary damages,
attorney’s 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 RTC had jurisdiction
over the case.

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