PANTRANCO NORTH EXPRESS v.

STANDARD INSURANCE

FACTS: Crispin Gicale was driving the passenger jeepney owned by his mother. Alexander Buncan, on the
other hand, was driving a bus owned by Pantranco North Express Inc. Both drivers were travelling along
the National Highway of Talavera, Nueva Ecija in a rainy afternoon. Buncan was driving the bus
northbound while Cripin was trailing behind. When the two vehicles were negotiating a curve along the
highway, the passenger bus overtook the jeepney. In so doing, thhe passenger bus hit the left rear side of
the jeepney and sped away.

Crispin reported the incident to the police and to the insurer of their jeepney, Standard Insurance
Co. The total cost of the repair amounted to P21, 415. Standard only paid P8,000 while Martina Gicale
shouldered the remaining P13,415. Thereafter, Standard and Martina demanded reimbursements from
Pantranco and Buncan, but the bus company and the driver refused. Thus, Standard and Martina were
prompted to file a complaint for sum of money with the RTC of Manila.

Pantranco and Buncan denied the allegations of the complaint and asserted that it is the MeTC
which has jurisdiction over the case.

RTC: Ruled in favor of Standard and Martina, and ordered Pantranco and Buncan to pay the former
reimbursements with interests due thereon plus attorney's fees, and litigation expenses.

Pantranco and Buncan: The RTC has no jurisdiction over the complaint.

1) Martina Gicale was claiming P13,415, while Standard was claiming P8,000. Their individual
claims are below P20,000. Thus, the case falls under the exclusive jurisdiction of the MTC.

2) There was a misjoinder of parties.

CA affirmed the decision of the RTC.

1) Under the Totality Rule provided for under Sec. 19 of BP 129, it is the sum of the two claims that
determines the jurisdictional amount. At the time this case was heard, cases involving money claims that
amounts to more than P20,000 falls under the exclusive jurisdiction of the RTC.

2) Even assuming that there was a misjoinder of parties, it does not affect the jurisdiction of the court
nor is it a ground to dismiss the complaint. The claims of Gicale and Standard arose from the same
vehicular accident involving Pantranco's bus and Gicale's jeepney. Thus, there was a question of fact
common to all parties.

Gicale and Standard: There was no misjoinder of parties. Their individual claims arose from the same
vehicular accident and involve a common question of fact and law. Thus, the RTC has jurisdiction over the
case.

ISSUE: WON there was a misjoinder of parties in the case.

HELD: No. Sec. 6, Rule 3 of the Revised Rules of Court provides the following requirements for a
permissive joinder of parties: (a) the right to relief arises out of the same transaction or series of
transactions; (b) there is a question of law or fact common to all the plaintiffs or defendants; and (c) such
joinder is not otherwise proscribed by the provisions of the Rules on jurisdiction and venue.
In this case, there is a single transaction common to all, that is, Pantranco’s bus hitting the rear side of the
jeepney. There is also a common question of fact, that is, whether petitioners are negligent. There being a
single transaction common to both respondents, consequently, they have the same cause of action against
petitioners.

To determine identity of cause of action, it must be ascertained whether the same evidence which is
necessary to sustain the second cause of action would have been sufficient to authorize a recovery in the
first. Here, had respondents filed separate suits against petitioners, the same evidence would have been
presented to sustain the same cause of action. Thus, the filing by both respondents of the complaint with
the court below is in order. Such joinder of parties avoids multiplicity of suit and ensures the convenient,
speedy and orderly administration of justice.

There is NO MISJOINDER OF PARTIES if the money sought to be claimed is in favor of the same plaintiff/s
and against the same defendant/s.

On the issue of lumping together the claims of Gicale and Standard, Section 5(d), Rule 2 of the same Rules
provides:

“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.”

Further, the Court reiterates the Totality rule exemplified by Sec. 33 (1) of BP 129: “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.”

Hence, PETITION IS DENIED.