Sante vs Claraval

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
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 aforesaidkilling. Thus, respondent prayed for the
following:Moral Damages 300,000 Exemplary Damages 50, 000 Attorneys fees50, 000
Litigation expenses 20, 000
Petitioners filed a motion to dismiss on the ground of jurisdiction. The trial court denied the motion.
Petitioner also filed petition for Certiorari and Prohibition before the CA, and their petition was granted.
The CA held that the demand for exemplary damages was merely incidental. Hence, this petition for
certiorari.
Petitioners insist that the complaint falls under the exclusive jurisdiction of the MTCC. They maintain
that 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. And having no jurisdiction over the subject matter of the case, the RTC acted
with grave abuse of discretion when it allowed the amendment of the complaint to increase the claim
for moral damages in order to confer jurisdiction.
Issue: should the amount of moral damages prayed for in the complaint be the sole basis for
determining which court has jurisdiction or should the total amount of all the damages claimed
regardless of kind and nature, such as exemplary damages, nominal damages, and attorneys
fees, etc., be used?
Held: The total amount of all the damages claimed regardless of kind and nature, such as exemplary
damages, nominal damages, and attorneys fees, etc., should be used. 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.
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.
Lastly, we find no error, much less grave abuse of discretion, on the part of the Court of Appeals in
affirming the RTCs order allowing the amendment of the original complaint from P300,000.00
toP1,000,000.00 despite the pendency of a petition for certiorari filed before the Court of
Appeals. While it is a basic jurisprudential principle that an amendment cannot be allowed when the
court has no jurisdiction over the original complaint and the purpose of the amendment is to confer
jurisdiction on the court, here, the RTC clearly had jurisdiction over the original complaint and
amendment of the complaint was then still a matter of right.

Sebastian vs Ng

The MCTC has the authority and jurisdiction to enforce the kasunduan regardless of the amount
involved. Section 417 made no distinction with respect to the amount involved or the nature of the
issue involved.
Facts: Respondent Annabel Ng filed a complaint before the barangay seeking to collect from Petitioner
Michael Sebastian the sum of P350,000.00 that she sent to Michael.
Respondent Annabel claimed that she and Michael were once sweethearts, and that they agreed to
jointly invest their financial resources to buy a truck. She alleged that while Annabel was working in
Hongkong, Annabel sent Michael the amount of P350,000.00 to purchase the truck. However, after
Annabel and Michael's relationship has ended, Michael allegedly refused to return the money to
Annabel, prompting the latter to bring the matter before the Barangay Justice. On July 9, 1997, the
parties entered into an amicable settlement, wherein Michael agreed to pay Annabel the amount of
P250,000.00 on specific dates.
Respondent filed with the MCTC a motion for execution after Michael failed to comply with their
agreement. The MCTC rendered a decision in favor Annabel ordering Michael to pay 250,000 as
evidenced by their agreement. Michael filed an appeal with the RTC, who upheld the decision of MCTC.
Michael filed a motion for reconsideration and has granted his petition and the MCTC decision was set
aside. The CA however reversed the decision and upheld the MCTC ruling.
Michael argues that kasunduan cannot be given the force and effect of a final judgment because it
did not conform to the provisions of theKatarungang Pambarangay law and it is merely in the nature of
a private document. He also reiterates that since the amount of P250,000.00 - the subject matter of
the kasunduan - is in excess of MCTC's jurisdictional amount of P200,000.00, the kasunduan is beyond
the MCTC's jurisdiction.
Issue:
Can the kasunduan be enforced by MCTC despite the amount involved is beyond its jurisdictional
authority to hear and resolve?
Held:
Yes, The MCTC has the authority and jurisdiction to enforce the kasunduan regardless of the amount
involved. Section 417 made no distinction with respect to the amount involved or the nature of the
issue involved. Thus, there can be no question that the laws intendment was to grant jurisdiction over
the enforcement of settlement/arbitration awards to the city or municipal courts the regardless of the
amount.
Moreover, Section 14, Rule VI of the Katarungang Pambarangay Implementing Rules states that the
partys failure to repudiate the settlement within the period of ten (10) days shall be deemed a waiver
of the right to challenge the settlement on the ground that his/her consent was vitiated by fraud,
violence or intimidation. In the present case, the records reveal that Michael never repudiated the
kasunduan within the period prescribed by the law. Hence, the CA correctly ruled that the kasunduan
has the force and effect of a final judgment that is ripe for execution.
Barrido vs Nonato
The MTCC has jurisdiction to take cognizance of real actions or those affecting title to real property, or
for the recovery of possession, or for the partition or condemnation of, or foreclosure of a mortgage on
real property.

Respondent Leonardo Nonato filed a Complaint for partition before the Municipal Trial Court in Cities
(MTCC) for a property situated in Eroreco, Bacolod City against former wife and petitioner Marietta
Barrido.
The parties are husband and wife who in the course of their marriage were able to acquire a property
situated in Eroreco, Bacolod City. On March 15, 1996, their marriage was declared void on the ground
of psychological incapacity. Since there was no more reason to maintain their co-ownership over the
property, Nonato asked Barrido for partition, but the latter refused. Barrido claimed, by way of
affirmative defense, that the subject property had already been sold to their children, Joseph Raymund
and Joseph Leo.
Petitioner moved for the dismissal of the complaint. MTCC ruled in favor of Barrido ordering that the
conjugal dwelling in controversy be adjudicated to the defendant Marietta Nonato. Nonato appealed
the MTCC decision and the Bacolod RTC reversed the ruling of the MTCC. The CA affirmed the RTC
Decision. Hence, Barrido brought the case to the Court via a Petition for Review.
Petitioner contends that the MTCC had no jurisdiction to hear the case because the partition case is an
action incapable of pecuniary estimation.
Issue: Can the MTCC exercise jurisdiction over the partition case?
Held: Yes, The MTCC has jurisdiction to take cognizance of real actions or those affecting title to real
property, or for the recovery of possession, or for the partition or condemnation of, or foreclosure of a
mortgage on real property. Section 33 of Batas Pambansa Bilang 129 provides Exclusive original
jurisdiction in all civil actions which involve title to, or possession of, real property, or any interest
therein where the assessed value of the propertyor interest therein does not exceed Twenty thousand
pesos (P20,000.00)or, in civil actions in Metro Manila, where such assessed value does not exceed Fifty
thousand pesos (P50,000.00) exclusive of interest, damages of whatever kind, attorney's fees,
litigation expenses and costs: Provided, That value of such property shall be determined by the
assessed value of the adjacent lots.
Here, the subject propertys assessed value was merely P8,080.00, an amount which certainly does
not exceed the required limit of P20,000.00 for civil actions outside Metro Manila tofall within the
jurisdiction of the MTCC. Therefore, the lower court correctly took cognizance of the instant case

Brgy. San Roque vs Heirs of Francisco Pastor

An expropriation suit is incapable of pecuniary estimation. Accordingly, it falls within the jurisdiction of
the regional trial courts
Petitioner filed before the Municipal Trial Court (MTC) of Talisay, Cebu a Complaint to expropriate a
property of the respondents who are the owners of the property in this case.
The MTC dismissed the Complaint on the ground of lack of jurisdiction. It reasoned that an action for
eminent domain is therefore within the exclusive original jurisdiction of the Regional Trial Court and not
with this Court." The RTC also dismissed the Complaint when filed before it, holding that an action for
eminent domain affected title to real property; hence, the value of the property to be expropriated
would determine whether the case should be filed before the MTC or the RTC. Concluding that the
action should have been filed before the MTC since the value of the subject property was less
than P20,000.
Petitioner appealed directly to this Court, raising a pure question of law.

Respondents contend that the Complaint for Eminent Domain affects the title to or possession of real
property. Thus, they argue that the case should have been brought before the MTC, pursuant to BP 129
as amended by Section 3 (3) of RA 7691. This law provides that MTCs shall have exclusive original
jurisdiction over all civil actions that involve title to or possession of real property, the assessed value
of which does not exceed twenty thousand pesos or, in civil actions in Metro Manila, fifty thousand
pesos exclusive of interest, damages of whatever kind, attorneys fees, litigation expenses and costs.
Issue: Should the RTC take cognizance in an expropriation case regardless of the value?
Held: Yes, An expropriation suit is incapable of pecuniary estimation. Accordingly, it falls within the
jurisdiction of the regional trial courts, regardless of the value of the subject property. The present
case, an expropriation suit does not involve the recovery of a sum of money. Rather, it deals with the
exercise by the government of its authority and right to take private property for public use.
It should be stressed that the primary consideration in an expropriation suit is whether the government
or any of its instrumentalities has complied with the requisites for the taking of private property.
Hence, the courts determine the authority of the government entity, the necessity of the expropriation,
and the observance of due process. In the main, the subject of an expropriation suit is the
governments exercise of eminent domain, a matter that is incapable of pecuniary estimation. To
emphasize, the question in the present suit is whether the government may expropriate private
property under the given set of circumstances. The government does not dispute respondents title to
or possession of the same. Indeed, it is not a question of who has a better title or right, for the
government does not even claim that it has a title to the property. It merely asserts its inherent
sovereign power to "appropriate and control individual property for the public benefit, as the public
necessity, convenience or welfare may demand.

Gonzales vs GJH land

Jurisdiction over the subjectmatter of a case is conferred by law, whereas a courts exercise
of jurisdiction, unless provided by the law itself, is governed by the Rules ofCourt or by the orders
issued from time to time by the Court.
Facts: Petitioners Manuel Luis C. Gonzales and Francis Martin D. Gonzales (petitioners) filed a
Complaint for Injunction with prayer for Issuance of Status Quo Order, Three (3) and Twenty (20)-Day
Temporary Restraining Orders, and Writ of Preliminary Injunction with Damages against respondents
GJH Land, Inc. (formerly known as S.J.Land, Inc.), Chang Hwan Jang, Sang Rak Kim, Mariechu N. Yap,
and Atty.Roberto P. Mallari II (respondents) before the RTC of Muntinlupa City seeking to enjoin the sale
of S.J. Land, Inc.s shares which they purportedly bought from S.J. Global, Inc. on February 1, 2010.
Essentially, petitioners alleged that the subscriptions for the said shares were already paid by them in
full in the books of S.J. Land, Inc., but were nonetheless offered for sale on July 29, 2011 to the
corporations stockholders, hence, their plea for injunction.
The case was raffled to Branch 276, which is not a special commercial court, and the same branch
granted petitioners writ of preliminary injunction. The respondents filed a motion to dismiss on the
ground of lack of jurisdiction over the subject matter because the case involves an intra-corporate
dispute. The RTC granted the motion to dismiss pointing out the it is Branch 256 which was assigned
as the Special commercial court; hence Branch 276 had no jurisdiction. Petitioners filed a motion for
reconsideration. The motion was denied, hence this petition.
Issue: Can branch 276 dismiss the case for lack of jurisdiction over the subject matter?

Held: No, branch 276 cannot dismiss the case for lack of jurisdiction over the subject matter.
Jurisdiction over the subjectmatter of a case is conferred by law, whereas a courts exercise
of jurisdiction, unless provided by the law itself, is governed by the Rules ofCourt or by the orders
issued from time to time by the Court. In Lozada v. Bracewell , it was recently held that the matter of
whether the RTCresolves an issue in the exercise of its general jurisdiction or of itslimited
jurisdiction as a special court is only a matter of procedure and has nothing to do with the
question of jurisdiction.
Further, jurisdiction over cases enumerated in Section 5 ofPresidential Decree No. 902-A was
transferred from the Securities and Exchange Commission (SEC) to the RTCs, being courts of
general jurisdiction.
It is, therefore, from the time of such filing that the RTC of Muntinlupa City acquired
jurisdiction over the subject matter or the nature of the action Unfortunately, the commercial
case was wrongly raffled to a regular branch, i.e., Branch276, instead of being assigned to
the sole Special Commercial Court inthe RTC of Muntinlupa City, which is Branch 256.
Similarly, the transfer of the present intra-corporate dispute fromBranch 276 to Branch 256
of the same RTC of Muntinlupa City, subjectto the parameters above-discussed is proper
and will further thepurposes stated in A.M. No. 03-03-03-SC of attaining a speedy
andefficient administration of justice.