Iniego Vs Purganan

ARTEMIO INIEGO vs. HON. JUDGE GUILLERMO G. PURGANAN and FOKKER C.
SANTOS
G. R. No. 166876 March 24, 2006
Fokker Santos while driving a jeepney was hit by a freight truck driven by Jimmy Pinion. He then filed for
quasi delict and damages against the driver and its owner (Artemio Iniego).
Santos filed a motion to declare defendant in default, failure to reply. Iniego filed motion to admit and
motion to dismiss, RTC has no jurisdiction over the cause of action. RTC of Manila thru Judge Purganan,
denied both the motions, except motion to admit. In the motion to admit, Iniego alleged that he did not
received the order that denied his extension of time. But believing that it was approved he filed the
additional motions. It was found that the order sent to Iniego was sent to a wrong address.
In Iniego’s Motion to Dismiss he claims that actions for damages based on quasi-delict are actions that
are capable of pecuniary estimation; hence, the jurisdiction in such cases falls upon either the municipal
courts (the Municipal Trial Courts, Metropolitan Trial Courts, Municipal Trial Courts In Cities, And
Municipal Circuit Trial Courts), or the Regional Trial Courts, depending on the value of the damages
claimed. He argues further that should this Court find actions for damages capable of pecuniary
estimation, then the total amount of damages claimed by the private respondent must exceed
P400,000.00 in order that it may fall under the jurisdiction of the RTC. Petitioner asserts, however, that
the moral (P300k) and exemplary damages (P150k) claimed by private respondent be excluded from the
computation of the total amount of damages for jurisdictional purposes because the said moral and
exemplary damages arose, not from the quasi-delict, but from the petitioner’s refusal to pay the actual
damages.
The RTC denied the Motion to Dismiss by Iniego twice. In appeal, the CA also denied it for lack of merit.
RULINGS:
1. Actions for damages based on quasi-delicts are primarily and effectively actions for the recovery
of a sum of money for the damages suffered because of the defendant’s alleged tortious acts,
and are therefore capable of pecuniary estimation.
According to respondent Judge, what he referred to in his assailed Order as not capable of pecuniary
estimation is the cause of action, which is a quasi-delict, and not the amount of damage prayed for.
From this, respondent Judge concluded that since fault or negligence in quasi-delicts cannot be the
subject of pecuniary estimation, the RTC has jurisdiction. The Court of Appeals affirmed respondent
Judge in this respect.
Respondent Judge’s observation is erroneous. It is crystal clear from B.P. Blg. 129, as amended by
Republic Act No. 7691, that what must be determined to be capable or incapable of pecuniary
estimation is not the cause of action, but the subject matter of the action.
The case of Lapitan v. Scandia, Inc., et al. in determining whether the subject matter of the action is
capable of pecuniary estimation:
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 courts of first instance [now Regional Trial Courts] would 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 like suits to have the defendant perform his part of the contract (specific performance)
and in actions for support, or for annulment of a judgment or to foreclose a mortgage, 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].
Actions for damages based on quasi-delicts are primarily and effectively actions for the recovery of a
sum of money for the damages suffered because of the defendant’s alleged tortious acts. We therefore
rule that the subject matter of actions for damages based on quasi-delict is capable of pecuniary
estimation.
2. The amount of damages claimed is within the jurisdiction of the RTC, since it is the claim for all
kinds of damages that is the basis of determining the jurisdiction of courts, whether the claims
for damages arise from the same or from different causes of action.
Despite our concurrence in petitioner’s claim that actions for damages based on quasi-delict are actions
that are capable of pecuniary estimation, we find that the total amount of damages claimed by the
private respondent nevertheless still exceeds the jurisdictional limit of P400,000.00 and remains under
the jurisdiction of the RTC.
All claims for damages should be considered in determining the jurisdiction of the court regardless of
whether they arose from a single cause of action or several causes of action. Rule 2, Section 5, of the
Rules of Court allows a party to assert as many causes of action as he may have against the opposing
party. Subsection (d) of said section provides that where the claims in all such joined causes of action are
principally for recovery of money, the aggregate amount claimed shall be the test of jurisdiction.
Jurisdiction in the case at bar remains with the RTC, considering that the total amount claimed, inclusive
of the moral and exemplary damages claimed, is P490,000.00.

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ARTEMIO INIEGO vs. HON. JUDGE GUILLERMO G. PURGANAN and FOKKER C.

G. R. No. 166876 March 24, 2006

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