SANTE V CLARAVALL

In April 5, 2004, Kalashian, the private respondent filed complaint against the Sante spouses when Mrs. Sante uttered malicious and
demeaning words against her and her friend. She also avers that the Sante spouses went around Natividad, Pangasinan telling people
that she is protecting and cuddling the suspects in the killing of their relative
Thus, respondent prayed that petitioners be held liable to pay moral damages in the amount of P300,000.00; P50,000.00 as exemplary
damages; P50,000.00 attorneys fees; P20,000.00 litigation expenses; and costs of suit.
Sante Spouses filed MTD on the ground that it was the Municipal Trial Court in Cities (MTCC) and not the RTC of Baguio, that had
jurisdiction over the case. 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.
The TC denied the motion and held that the total claim of respondent amounted to P420,000.00 which was above the jurisdictional
amount for MTCCs outside Metro Manila.
Petitioners filed a Petition for Certiorari and Prohibition with the CA
on July 14, 2004, respondent and her husband filed an Amended Complaint [11] increasing the claim for moral damages
from P300,000.00 to P1,000,000.00.
Sante Spouses filed MTD but was denied again
petitioners again filed a Petition for Certiorari and Prohibition
JAN 23,2006- The CA granted the petitioners (1 ST) Motion and held that the case clearly falls under the jurisdiction of the MTCC as the
allegations show that plaintiff was seeking to recover moral damages in the amount of P300,000.00, which amount was well within the
jurisdictional amount of the MTCC. The Court of Appeals added that the totality of claim rule used for determining which court had
jurisdiction could not be applied to the instant case because plaintiffs claim for exemplary damages was not a separate and distinct cause of
action from her claim of moral damages, but merely incidental to it. Thus, the prayer for exemplary damages should be excluded in
computing the total amount of the claim.
JANUARY 31,2006 The CA denied the petitioners (2ND) Motion court held that the total or aggregate amount demanded in the
complaint constitutes the basis of jurisdiction.
The Court of Appeals additionally ruled that respondent can amend her complaint by increasing the amount of moral damages
from P300,000.00 to P1,000,000.00, on the ground that the trial court has jurisdiction over the original complaint and respondent is
entitled to amend her complaint as a matter of right under the Rules.
Hence, this petition.
ISSUE:
1)
2)

Did the RTC acquire jurisdiction over the case? and

Did the RTC commit grave abuse of discretion in allowing the amendment of the complaint?

SC RULING:
We deny the petition, which although denominated as a petition for certiorari, we treat as a petition for review on certiorari under Rule
45 in view of the issues raised.
SEC. 19. Jurisdiction in civil cases. Regional Trial Courts shall exercise exclusive original jurisdiction:
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(8) In all other cases in which the demand, exclusive of interest, damages of whatever kind, attorneys fees, litigation
expenses, and costs or the value of the property in controversy exceeds One hundred thousand pesos (P100,000.00)
or, in such other cases in Metro Manila, where the demand, exclusive of the abovementioned items exceeds Two
hundred thousand pesos (P200,000.00).
Section 5 of Rep. Act No. 7691 further provides:
SEC. 5. After five (5) years from the effectivity of this Act, the jurisdictional amounts mentioned in Sec. 19(3), (4),
and (8); and Sec. 33(1) of Batas Pambansa Blg. 129 as amended by this Act, shall be adjusted to Two hundred
thousand pesos (P200,000.00). Five (5) years thereafter, such jurisdictional amounts shall be adjusted further to
Three hundred thousand pesos (P300,000.00): Provided, however, That in the case of MetroManila, the
abovementioned jurisdictional amounts shall be adjusted after five (5) years from the effectivity of this Act to Four
hundred thousand pesos (P400,000.00).
By virtue of the SC circular issued pursuant to RA 7691:
March 20,1999 200k
Feb 22,20114- 300k
In this regard, Administrative Circular No. 09-94[19] is instructive:
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2. The exclusion of the term damages of whatever kind in determining the jurisdictional amount under Section 19
(8) and Section 33 (1) of B.P. Blg. 129, as amended by R.A. No. 7691, 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. (Emphasis ours.)
It is settled that 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.