24.

MANGALIG vs CATUBIG-PASTORAL

Facts:

Respondent Serquina filed a complaint for damages with the RTC against petitioners Mangaliag and Solano. This
complaint alleges that the Serquina and his co-passengers sustained serious injuries and permanent deformities from
the collision of their tricycle with the petitioners dump truck and the gross negligence, carelessness and imprudence
of the petitioners in driving the dump truck. Respondents seek damages in the form of medical expenses amounting
to P71,392.00. Respondents also claim P500,000.00 by way of moral damages, as a further result of his hospitalization,
lost income of P25,000.00 or the nominal damages, and attorneys fees.

Petitioners filed their answer with counterclaim. After pre-trial conference, trial on the merits ensued. After the
respondent rested his case, petitioners testified in their defense. Subsequently, petitioners filed a motion to dismiss
on the ground of lack of jurisdiction over the subject matter. They alleged that since the principal amount prayed for,
in the amount of P71,392.00, falls within the jurisdiction of MTC. Petitioners maintain that the courts jurisdiction
should be based exclusively on the amount of actual damages, excluding therefrom the amounts claimed as moral,
exemplary, nominal damages and attorneys fee, etc.

The respondent opposed the motion saying that since the claim for damages is the main action, the totality of the
damages sought to be recovered should be considered in determining jurisdiction. He relied on Administrative Circular
No. 09-94 which provides that in cases where the claim for damages is the main cause of action. . . the amount of
such claim shall be considered in determining the jurisdiction of the court Also, the petitioners defense of lack of
jurisdiction has already been barred by estoppel and laches. He contends that after actively taking part in the trial
proceedings and presenting a witness to seek exoneration, it would be unfair and legally improper for petitioners to
seek the dismissal of the case.

RTC ruled in favor of respondent. Petitioners filed an MR which was denied. Subsequently, they filed a petition for
certiorari with the SC.

Issues:
Whether petitioners are barred from raising the defense of the RTCs lack of jurisdiction? NO
Whether it is the amount of P71,392.00 as medical expenses, excluding moral, nominal damages and
attorneys fees, which determines jurisdiction, hence it is MTC which has jurisdiction? NO

Ruling:
On the matter of estoppel and laches: In the present case, no judgment has yet been rendered by the RTC. As
a matter of fact, as soon as the petitioners discovered the alleged jurisdictional defect, they did not fail or
neglect to file the appropriate motion to dismiss. Hence, finding the pivotal element of laches to be absent,
the Sibonghanoy doctrine does not control the present controversy. What happened in the Sibonghanoy, the
party invoking lack of jurisdiction did so only after fifteen years and at a stage when the proceedings had
already been elevated to the CA. Sibonghanoy is an exceptional case because of the presence of laches. But
in this case, there is no laches. Thus, the general rule that the question of jurisdiction of a court may be raised
at any stage of the proceedings must apply. Petitioners are not estopped from questioning the jurisdiction
of the RTC.

On the issue which of the amounts is determinative of jurisdiction: 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 of
the claims or reliefs sought therein. In the present case, the allegations in the 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 respondents 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.

If the rule were otherwise, i.e., the courts jurisdiction in a case of quasi-delict causing physical injuries would
only be based on the claim for actual damages and the complaint is filed in the MTC, it can only award moral
damages in an amount within its jurisdictional limitations, a situation not intended by the framers of the law.