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IRENE SANTE AND REYNALDOSANTE vs. HON. EDILBERTO T.

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

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.

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

amendment is to confer jurisdiction on the court (Siasoco v. Court of


Appeals, G.R. No. 132753, February 15, 1999, 303 SCRA 186,
196), the RTC in the case clearly had jurisdiction over the original
complaint and the amendment of the complaint was then still a
matter of right under Section 2, Rule 10 of the Rules of Court. Ergo,
the amendment of the complaint was in order

G.R. No. 176492, October 20, 2014,


MARIETTA N. BARRIDO, PETITIONER, vs. LEONARDO V.
NONATO, RESPONDENT

Facts: Leonardo and Marrietas marriage was dissolved by reason of


psychologyical incapacity in 1996, hence Leonardo filed a complaint
for partition over their property consisting of a house and lot, since
according to him, there was no more reason to maintain their coownership. In her defense, Marrieta claimed that the property had
been sold to their children Joseph Raymond and Joseph Leo. She
also moved for dismissal of the action for lack of jurisdiction on the
part of the MTCC Bacolod City, the action for partition being an
action incapable of pecuniary estimation. Per decision of the MTCC,
it ruled in favour of Marrietta and adjudicated the land to her, being
the spouse with whom the majority of the common children choose
to remain. It also awarded moral damages in favour of Marrieta.
Leonardo appealed the ruling to the RTC, which reversed the MTCC
ruling and ordered the partition of the property, hence Marrieta
appealed the RTC decision to the Court of Appeals by petition for
review. The appellate court denied Mariettas appeal, ruling that
since the assessed value of the property is only P8,080.00, it clearly

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.

Marrieta elevated her case to the Supreme Court.


Held: The Supreme Court:
Contrary to Barridos contention, 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:
Section 33. Jurisdiction of Metropolitan Trial Courts, Municipal Trial
Courts and Municipal Circuit Trial Courts in civil cases.
Metropolitan Trial Courts, Municipal Trial Courts, and Municipal
Circuit Trial Courts shall exercise:
xxxx
(3) 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 property or 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,
attorneys fees, litigation expenses and costs: Provided, That value
of such property shall be determined by the assessed value of the
adjacent lots. (as amended by R.A. No. 7691)
Here, the subject propertys assessed value was merely P8,080.00,
an amount which certainly does not exceed the required limit of

G.R. No. L-2352

July 26, 1910

ELADIO ALONSO, vs. TOMAS VILLAMOR, ET AL.,

Overview: Members of the municipal board of the municipality of


Placer (defendants) took from Father Alonso (plaintiff), priest in
charge, possession of the church and its appurtenances, and also all
of the personal property contained therein. Father Alonso then
brought an action to recover from the defendants the value of certain
articles from the church and the rental value of the premises during
the occupation of the defendants. LC decided in his favor. According
to the defendants-appellants, the church and the articles within it was
owned by the municipality as these were built and purchased by
funds voluntarily contributed by the people of the municipality. They
also claimed that Father Alonso was not a real party in interest. SC
affirmed the ruling of the LC saying that at the time of taking, the
property in question belonged to the Roman Catholic Church. SC
also declared that Father Alonso is not the real party in interest as he
personally has no interest in the cause of action. However, SC
ordered that the action be amended by substituting the Roman
Catholic Apostolic Church in the place and stead of Father Alonso as
party plaintiff for the reason that the amendment does not constitute
change in the identity of the parties but just a formal substitution.
Statement of the 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.

The Roman Catholic Church against the municipality of Placer


(September 23, 1908): Court ruled that the property belonged to the
Roman Catholic Church.
Barlin v Ramirez, Municipality of Ponce v Roman Catholic Apostolic
Church in Porto Rico
It is undoubted that the bishop of the diocese or the Roman Catholic
Apostolic Church itself is the real party in interest. The plaintiff
personally has no interest in the cause of action.
Sec. 114 of the Code of Civil Procedure: Every action must be
prosecuted in the name of the real party in interest.
This Court has full power, apart from that power and authority which
is inherent, to amend the process, pleadings, proceedings, and
decision in this case by substituting, as party plaintiff, the real party in
interest. Not only are we confident that we may do so, but we are
convinced that we should do so.
Sec. 110 of the Code of Civil Procedure: Amendments in general.
The court shall, in furtherance of justice, and on such terms, if any,
as may be proper, allow a party to amend any pleading or
proceeding and at any stage of the action, in either the Court of First
Instance or the Supreme Court, by adding or striking out the name of
any party, either plaintiff or defendant, or by correcting a mistake in
the name of a party, or a mistaken or inadequate allegation or
description in any other respect so that the actual merits of the
controversy may speedily be determined, without regard to
technicalities, and in the most expeditious, and inexpensive manner.
The court may also, upon like terms, allow an answer or other
pleading to be made after the time limited by the rules of the court for
filing the same. Orders of the court upon the matters provided in this
section shall be made upon motion filed in court, and after notice to
the adverse party, and an opportunity to be heard.

Sec. 503: Judgment not to be reversed on technical grounds. No


judgment shall be reversed on formal or technical grounds, or for
such error as has not prejudiced the real rights of the excepting
party.
Such an amendment does not constitute a change in the identity of
the parties.
The plaintiff asserts in his complaint, and maintains that assertion all
through the record, that he is engaged in the prosecution of this
case, not for himself, but for the bishop of the diocesenot by his
own right, but by right of another. He seeks merely to do for the
bishop what the bishop might do for himself. His own personality is
not involved. His own rights are not presented. He claims no interest
whatever in the litigation. He seeks only the welfare of the great
church whose servant he is. Gladly permits his identity to be wholly
swallowed up in that of his superior.
Formal substitution - Substitution so as to make the form express the
substance
No one is deceived for an instant as to whose interest are at stake.
The form of its expression is alone defective.
Form is a method of speech used to express substance and make it
clearly appear. It is the means by which the substance reveals itself.
If the form be faulty and still the substance shows plainly through no,
harm can come by making the form accurately expressive of the
substance.
No one has been misled by the error in the name of the party
plaintiff. If we should by reason of this error send this back for
amendment and new trial, there would be on the retrial the same
complaint, the same answer, the same defense, the same interests,
the same witnesses, and the same evidence. The name of the
plaintiff would constitute the only difference between the old trial and
the new. In our judgment there is not enough in a name to justify
such action.

There is nothing sacred about processes or pleadings, their forms or


contents. Their sole purpose is to facilitate the application of justice
to the rival claims of contending parties. They were created, not to
hinder and delay, but to facilitate and promote, the administration of
justice. The error in this case is purely technical. To take advantage
of it for other purposes than to cure it, does not appeal to a fair sense
of justice. Technicality, when it desserts its proper office as an aid to
justice and becomes its great hindrance and chief enemy, deserves
scant consideration from courts. There should be no pvested rights in

technicalities. No litigant should be permitted to challenge a record of


a court of these Islands for defect of form when his substantial rights
have not been prejudiced thereby.

Judgment: Process, pleadings, proceedings and decision in this


action is amended by substituting the Roman Catholic Apostolic
Church in the place and stead of Alonso as party plaintiff. Decision of
the court below, so amended, is affirmed.