CLARAVALL,
G.R. No. 173915, February 22, 2010, VILLARAMA, JR., J.
Topic: Jurisdiction
Nature: Petition for certiorari
Facts:
1) 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
In Irene Sante vs. Hon. Claravall, the Supreme Court stated that
since at the time of the filing of the complaint on April 5, 2004, the
MTCCs jurisdictional amount has already been adjusted
to P300,000.00, there is no doubt that the Regional Trial Court (RTC)
has jurisdiction over the case since the total amount of damages
being claimed by the petitioner in the case was P420,000.00.
Moreover, in the said case the Supreme Court found 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 fromP300,000.00 to P1,000,000.00 despite the
pendency of a petition for certiorari filed before the Court of Appeals.
The High Court declared that 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
fell within the MTCC jurisdiction. Though the RTC applied Art. 129
instead of Art. 147 thereof, it still correctly ordered the partition of the
property.
P20,000.00 for civil actions outside Metro Manila to fall within the
jurisdiction of the MTCC. Therefore, the lower court correctly took
cognizance of the instant case.
The court below gave judgment in favor of the plaintiff for the sum of
P1,581, with interest at 6% from the date of the judgment. Said sum
was made up of two items: (1) P741 value of the articles taken
from the church; (2) P840 rental value of the premises during the
occupation by defendants.
Statement of Facts
December 11, 1901: Defendants (Villamor, et. al) who were members
of the municipal board of the municipality of Placer addressed to the
plaintiff (Alonso, priest in charge of the church) a letter stating the
following:
We have received an order from the provincial fiscal which says: The
cemeteries, convents, and the other buildings erected on land
belonging to the town at the expense of the town and preserved by it
belong to the town, and for this reason the municipality is under the
obligation of administering them and of collecting the revenues
therefrom, and for this reason we notify you that from this date all of
the revenues and products therefrom must be turned into the
treasury of the municipality in order that the people may properly
preserve them.
We notify you that the image of St. Vicente which is now in the
church, as it is an image donated to the people by its owner, by
virtue of said order is also the property of said people, and therefore
the alms which are given it by the devotees thereof must be also
turned into the municipal treasury for the proper preservation of the
church and for other necessary purposes. We hope that you will view
in the proper light and that you will deliver to the bearer of this letter
the key of the alms box of the said image in order that we may
comply with our obligation in conformity with the dispositions of said
order.
December 13, 1901: Defendants took possession of the church and
its appurtenances, and also all of the personal property contained
therein. The plaintiff protested against the occupation but his protests
received no consideration so he was summarily removed from
possession of the same. An action was brought by the plaintiff to
recover of the defendants the (1) value of certain articles taken from
the church, and (2) the rental value of the church and its
appurtenances, including the church cemetery from December 11,
1901 April 1904. LC ruled in favor of the plaintiff.
Defendants: (1) Plaintiff is not the real party in interest (Action should
have been in the name of the bishop of the diocese within the church
was located, or in the name of the Roman Catholic Apostolic Church,
as the real party in interest); (2) The church had been erected by
funds voluntarily contributed by the people of the municipality, and
that the articles within the church had been purchased with funds
raised in like manner, therefore, the municipality was the owner
thereof.
Applicable Laws: Secs. 114, 110 and 503 of the Code of Civil
Procedure (used in this case)
Issues:
WON the church and its appurtenances, and personal property
contained therein belonged to the municipality of Placer (No)
WON the plaintiff, R.P. Alonso, is the real party in interest (No)
WON the Court can substitute as party plaintiff the real party in
interest (Yes)
Rationale
The property sued for was, at the time it was taken by the
defendants, the property of the Roman Catholic Church, and that the
seizure of the same and occupation of the church and its
appurtenances by the defendants were wrongful and illegal. The
conclusions of the court below as to the value of the articles taken by
the defendants and of the rent of the church for the time of its illegal
occupation by the defendants were also correct and proper.