Sante vs Claraval

Facts:
In April 2004, private respondent Vita Kalashian filed before RTC Baguio a complaint
for damages against petitioners Irene Sante and Reynaldo Sante. Respondent
alleged that while she was inside the Police Station in Pangasinan, and in the
presence of other persons and police officers, Irene Sante uttered the words, How
many rounds of sex did you have last night with your boss, Bert? You fuckin bitch!
Bert refers to a friend of the respondent and one of her hired security guards in said
station, and a suspect in the killing of petitioners close relative. Petitioners also
allegedly went around Pangasinan telling people that she is protecting and cuddling
the suspects in the aforesaid killing. Thus, respondent prayed for the following:
Moral Damages Exemplary Damages Attorneys fees Litigation expenses 300,000
50, 000 50, 000 20, 000 2) Petitioners filed a motion to dismiss on the ground of
jurisdiction. They claimed that the Municipal Trial Court in Cities instead of RTC
Baguio should take cognizance. 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. 3)
The trial court denied the motion to dismiss on the ground that the amount of
demand P420,000 was above the jurisdictional amount for MTCCs outside Metro
Manila. 4) Petitioners filed a petition for certiorari and prohibition with the CA.
Meanwhile, respondent filed an amended complaint increasing the claim for moral
damages to P1,000,000. Petitioners then filed a motion to dismiss which was
denied. 5) Petitioners AGAIN filed a petition for certiorari and prohibition with the
CA, raising that RTC Baguio committed grave abuse of discretion in allowing the
amended complaint. CA ruled in favor of petitioners, stating that MTCC had
jurisdiction because considering ONLY the demand for P300,000 moral damages.
The CA held that the demand for exemplary damages was merely incidental. 6)
Hence, this petition for certiorari.
Issues: Whether RTC acquired jurisdiction of the case Whether RTC committed
grave abuse of discretion in allowing the amended complaint
Held:

YES. RTC acquired jurisdiction. Hence, there was no grave abuse of discretion. Ratio
Decidendi: PETITIONERS CONTENTION: The claim for moral damages, in the amount
of P300,000.00 in the original complaint, is the main action. The exemplary
damages being discretionary should not be included in the computation of the
jurisdictional amount. Thus, RTC acted with grave abuse of discretion in allowing the
amended complaint. RESPONDENTS CONTENTION: The nature of her complaint is
for recovery of damages. As such, the totality of the claim for damages, including
the exemplary damages as well as the other damages alleged and prayed in the
complaint, such as attorneys fees and litigation expenses, should be included in
determining jurisdiction. The exclusion of the term damages of whatever kind in
determining the jurisdictional amount under B.P. Blg. 129 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. In the instant case, the complaint filed is for the
recovery of damages for the acts of the petitioners. The complaint principally
sought an award of moral and exemplary damages, as well as attorneys fees and
litigation expenses, for the alleged shame and injury suffered by respondent.
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. It is clear, based on the allegations of the complaint, that
respondents main action is for damages.
Hence, the other forms of damages being claimed by respondent, e.g., exemplary
damages, attorneys fees and litigation expenses, are not merely incidental to or
consequences of the main action but constitute the primary relief prayed for in the
complaint. Considering that the total amount of damages claimed was P420,000.00,
the Court of Appeals was correct in ruling that the RTC had jurisdiction over the
case.