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PANTRANCO v.

BUNCAN
March 16, 2005 | Sandoval-Gutierrez, J. | Pleadings; Application of Section 33(1)

PETITIONERS: PANTRANCO NORTH EXPRESS, INC., and ALEXANDER BUNCAN


RESPONDENTS: STANDARD INSURANCE COMPANY, INC., and MARTINA GICALE

SUMMARY: A Pantranco bus hit a jeepney insured by Standard Insurance. Standard partially paid for the repairs, while the
jeepney owner (Gicale) paid for the balance. Standard and Gicale filed one complaint against Pantranco and the bus driver
(Buncan) after both refused to pay the total amount of the repairs. Pantranco and Buncan argued that Standards and Gicales
claims, taken individually, amount to less than 20K each; therefore jurisdiction is with MeTC. Standard and Gicale argue that they
have a common cause of action; therefore their claims can be lumped together to equal more than 20K; therefore jurisdiction is
with the RTC. Court held that the vehicular accident is a common cause of action for Standard and Gicale, therefore there may be
joinder of causes of action and claims can be combined to total more than 20K, which is within jurisdiction of RTC.

DOCTRINE:
Several claims with an identical cause of action that are contained in the same complaint may be lumped together to determine the
jurisdictional amount of a case.

RULE:

Section 5(d), Rule 2 ROC

Sec. 5. Joinder of causes of action. A party may in one pleading assert, in the alternative or otherwise, as many causes of action as
he may have against an opposing party, subject to the following conditions:

xxx

(d) Where the claims in all the causes of action are principally for recovery of money the aggregate amount claimed shall be the test
of jurisdiction.

BP 129 Sec 33(1)

xxx where there are several claims or causes of action between the same or different parties, embodied in the same complaint, the
amount of the demand shall be the totality of the claims in all the causes of action, irrespective of whether the causes of action
arose out of the same or different transactions.
FACTS:
1. A Pantranco bus (driven by Buncan) hit the back of a jeepney (owned by Gicale and driven by her son) while it was
trying to overtake the latter, and then sped away.

2. Standard Insurance partially paid for the repairs (Php 8000 out of Php 21,415). Gicale shouldered the balance of
Php 13,415. Standard Insurance and Gicale demanded reimbursement of the total cost of repairs from Pantranco
and Buncan, but both refused.

3. Standard Insurance and Gicale then filed a single complaint (IMPT!) for sum of money with RTC of Manila.

4. Pantranco and Buncan argue that it is the MeTC and not the RTC, which has jurisdiction over the case.

5. Trial court ruled in favor of Standard and Gicale.

6. Upon appeal, Pantranco and Buncan argued that Standard Insurances claim of P8K, and Gicales claim of P13K,
taken individually fall under the exclusive original jurisdiction of the MeTC.

7. CA disagreed. Ruling that under the Totality Rule (Sec. 19, BP 129), it is the sum of the two claims that
determines jurisdictional amount. Total is more than 20K, therefore within the jurisdiction of RTC.

8. Standard and Gicale also argue that their individual claims arose out of the same transaction, i.e., the vehicular
accident. Pantranco and Gicale argue otherwise (that the claims did NOT arise out of the same transaction and
must therefore be taken separately).

9. Digesters Note: Why is this important: If the cause of action arises from the same transaction, there may be
permissive joinder (under R3, S6). Once permissive joinder is allowed, their claims may be lumped together. Once
combined, the total claim amounts to more than 20K, placing the case of Standard and Gicale under the
jurisdiction of the RTC.

ISSUES/HELD
WON in determining the jurisdictional amount of the case, the claims of Standard and Gicale may be lumped together
on the basis of identity of cause of action, thus placing jurisdiction with the RTC. YES

HELD

There is identity of cause of action. There being a single transaction common to both Standard and Gicale (i.e.,
bus hitting jeepney), they have the same cause of action against Pantranco and Buncan. Thus, the amount of the
demand shall be the totality of the claims.

o To determine identity of cause of action, it must be ascertained whether the same evidence which is necessary to
sustain the 2nd cause of action would have been sufficient to authorize a recovery in the 1 st. (In other words, if the
two file separate suits, the same evidence would be presented). Thus, joinder of causes of action is proper (and
avoids multiplicity of suits).

One of the conditions in a joinder of causes of action is that where the claims in all the causes of action are principally for
recovery of money, the aggregate amount claimed shall be the test of jurisdiction. (Sec. 5(d), Rule 2)

Sec. 5, Rule 2 presupposes that the joint causes of action accrue in favor of the same plaintiffs against the same
defendants and that there is no misjoinder of parties.

Relate this to Sec 33 (1) BP 129, which provides that where there are several causes of action in one complaint, the
amount of the demand shall be the totality of the claims in all the causes of actions.

The total claims of Standard and Gicale = P21,415.

BP 129 provides that the RTC has exclusive jurisdiction over all other cases, in which the demand (excluding interest and
cost of property) is more than P20,000.
Therefore RTC has jurisdiction over this case.