IRENE SANTE AND REYNALDOSANTE vs. HON. EDILBERTO T. claim for moral damages to P1,000,000.

ral damages to P1,000,000. Petitioners then filed a motion

CLARAVALL, to dismiss which was denied.
G.R. No. 173915, February 22, 2010, VILLARAMA, JR., J.
Topic: Jurisdiction 5) Petitioners AGAIN filed a petition for certiorari and prohibition with
Nature: Petition for certiorari the CA, raising that RTC Baguio committed grave abuse of discretion
Facts: in allowing the amended complaint. CA ruled in favor of petitioners,
stating that MTCC had jurisdiction because considering ONLY the
1) In April 2004, private respondent Vita Kalashian filed before RTC demand for P300,000 moral damages. The CA held that the demand
Baguio a complaint for damages against petitioners Irene Sante and for exemplary damages was merely incidental.
Reynaldo Sante. Respondent alleged that while she was inside the
Police Station in Pangasinan, and in the presence of other persons 6) Hence, this petition for certiorari.
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!” Issues:
Bert refers to a friend of the respondent and one of her hired security Whether RTC acquired jurisdiction of the case
guards in said station, and a suspect in the killing of petitioners’ close
relative. Whether RTC committed grave abuse of discretion in allowing the
amended complaint
Petitioners also allegedly went around Pangasinan telling people that
she is protecting and cuddling the suspects in the aforesaid killing. Held: YES. RTC acquired jurisdiction. Hence, there was no grave
Thus, respondent prayed for the following: abuse of discretion.

Moral Damages 300,000 Ratio Decidendi:

Exemplary Damages 50, 000
Attorney’s fees 50, 000 PETITIONERS’ CONTENTION: The claim for moral damages, in the
amount of P300,000.00 in the original complaint, is the main action.
Litigation expenses 20, 000
The exemplary damages being discretionary should not be included
in the computation of the jurisdictional amount. Thus, RTC acted with
2) Petitioners filed a motion to dismiss on the ground of jurisdiction. grave abuse of discretion in allowing the amended complaint.
They claimed that the Municipal Trial Court in Cities instead of RTC RESPONDENT’S CONTENTION: The nature of her complaint is for
Baguio should take cognizance. They argued that the amount of the recovery of damages. As such, the totality of the claim for damages,
claim for moral damages was not more than the jurisdictional amount including the exemplary damages as well as the other damages
of P300,000.00, because the claim for exemplary damages should be alleged and prayed in the complaint, such as attorney’s fees and
excluded in computing the total claim. litigation expenses, should be included in determining jurisdiction.

3) The trial court denied the motion to dismiss on the ground that the The exclusion of the term “damages of whatever kind” in determining
amount of demand P420,000 was above the jurisdictional amount for the jurisdictional amount under B.P. Blg. 129 applies to cases where
MTCC’s outside Metro Manila. the damages are merely incidental to or a consequence of the main
cause of action. However, in cases where the claim for damages is
4) Petitioners filed a petition for certiorari and prohibition with the CA. the main cause of action, or one of the causes of action, the amount
Meanwhile, respondent filed an amended complaint increasing the
of such claim shall be considered in determining the jurisdiction of the amendment is to confer jurisdiction on the court (Siasoco v. Court of
court. Appeals, G.R. No. 132753, February 15, 1999, 303 SCRA 186,
196), the RTC in the case clearly had jurisdiction over the original
In the instant case, the complaint filed is for the recovery of damages complaint and the amendment of the complaint was then still a matter
for the acts of the petitioners. The complaint principally sought an of right under Section 2, Rule 10 of the Rules of Court. Ergo, the
award of moral and exemplary damages, as well as attorney’s fees amendment of the complaint was in order
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 plaintiff’s causes of action. It is clear,
based on the allegations of the complaint, that respondent’s main G.R. No. 176492, October 20, 2014,
MARIETTA N. BARRIDO, PETITIONER, vs. LEONARDO V.
action is for damages. Hence, the other forms of damages being
NONATO, RESPONDENT
claimed by respondent, e.g., exemplary damages, attorney’s fees and
litigation expenses, are not merely incidental to or consequences of Facts: Leonardo and Marrieta’s marriage was dissolved by reason of
the main action but constitute the primary relief prayed for in the psychologyical incapacity in 1996, hence Leonardo filed a complaint
complaint. for partition over their property consisting of a house and lot, since
according to him, there was no more reason to maintain their co-
Considering that the total amount of damages claimed was ownership. In her defense, Marrieta claimed that the property had
P420,000.00, the Court of Appeals was correct in ruling that the RTC been sold to their children Joseph Raymond and Joseph Leo. She
had jurisdiction over the case. 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,
In Irene Sante vs. Hon. Claravall, the Supreme Court stated that since it ruled in favour of Marrietta and adjudicated the land to her, being
at the time of the filing of the complaint on April 5, 2004, the MTCC’s the spouse with whom the majority of the common children choose
jurisdictional amount has already been adjusted to P300,000.00, there to remain. It also awarded moral damages in favour of Marrieta.
is no doubt that the Regional Trial Court (RTC) has jurisdiction over
the case since the total amount of damages being claimed by the
Leonardo appealed the ruling to the RTC, which reversed the MTCC
petitioner in the case was P420,000.00.
ruling and ordered the partition of the property, hence Marrieta
Moreover, in the said case the Supreme Court found no error, appealed the RTC decision to the Court of Appeals by petition for
much less grave abuse of discretion, on the part of the Court of review. The appellate court denied Marietta’s appeal, ruling that
Appeals in affirming the RTC’s order allowing the amendment of the since the assessed value of the property is only P8,080.00, it clearly
original complaint fromP300,000.00 to P1,000,000.00 despite the fell within the MTCC jurisdiction. Though the RTC applied Art. 129
pendency of a petition for certiorari filed before the Court of Appeals. instead of Art. 147 thereof, it still correctly ordered the partition of the
property.
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 Marrieta elevated her case to the Supreme Court.
Held: The Supreme Court:
G.R. No. L-2352 July 26, 1910
ELADIO ALONSO, vs. TOMAS VILLAMOR, ET AL.,
“Contrary to Barrido’s contention, the MTCC has jurisdiction to take
cognizance of real actions or those affecting title to real property, or Overview: Members of the municipal board of the municipality of
for the recovery of possession, or for the partition or condemnation Placer (defendants) took from Father Alonso (plaintiff), priest in
of, or foreclosure of a mortgage on real property. Section 33 of Batas charge, possession of the church and its appurtenances, and also all
Pambansa Bilang 129 provides: 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
Section 33. Jurisdiction of Metropolitan Trial Courts, Municipal Trial
occupation of the defendants. LC decided in his favor. According to
Courts and Municipal Circuit Trial Courts in civil cases. – the defendants-appellants, the church and the articles within it was
Metropolitan Trial Courts, Municipal Trial Courts, and Municipal owned by the municipality as these were built and purchased by funds
Circuit Trial Courts shall exercise: voluntarily contributed by the people of the municipality. They also
xxxx 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
(3) Exclusive original jurisdiction in all civil actions which involve title
that Father Alonso is not the real party in interest as he personally has
to, or possession of, real property, or any interest therein where the
no interest in the cause of action. However, SC ordered that the action
assessed value of the property or interest therein does not exceed
be amended by substituting the Roman Catholic Apostolic Church in
Twenty thousand pesos (P20,000.00) or, in civil actions in Metro
the place and stead of Father Alonso as party plaintiff for the reason
Manila, where such assessed value does not exceed Fifty thousand
that the amendment does not constitute change in the identity of the
pesos (P50,000.00) exclusive of interest, damages of whatever kind,
parties but just a formal substitution.
attorney’s fees, litigation expenses and costs: Provided, That value
of such property shall be determined by the assessed value of the Statement of the Case
adjacent lots. (as amended by R.A. No. 7691)
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
Here, the subject property’s assessed value was merely P8,080.00, was made up of two items: (1) P741 – value of the articles taken from
an amount which certainly does not exceed the required limit of the church; (2) P840 – rental value of the premises during the
P20,000.00 for civil actions outside Metro Manila to fall within the occupation by defendants.
jurisdiction of the MTCC. Therefore, the lower court correctly took
Statement of Facts
cognizance of the instant case.
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 Applicable Laws: Secs. 114, 110 and 503 of the Code of Civil
cemeteries, convents, and the other buildings erected on land Procedure (used in this case)
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 Issues:
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 WON the church and its appurtenances, and personal property
of the municipality in order that the people may properly preserve contained therein belonged to the municipality of Placer (No)
them.
WON the plaintiff, R.P. Alonso, is the real party in interest (No)
We notify you that the image of St. Vicente which is now in the church,
WON the Court can substitute as party plaintiff the real party in interest
as it is an image donated to the people by its owner, by virtue of said
(Yes)
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 Rationale
light and that you will deliver to the bearer of this letter the key of the
The property sued for was, at the time it was taken by the defendants,
alms box of the said image in order that we may comply with our
the property of the Roman Catholic Church, and that the seizure of the
obligation in conformity with the dispositions of said order.
same and occupation of the church and its appurtenances by the
December 13, 1901: Defendants took possession of the church and defendants were wrongful and illegal. The conclusions of the court
its appurtenances, and also all of the personal property contained below as to the value of the articles taken by the defendants and of
therein. The plaintiff protested against the occupation but his protests the rent of the church for the time of its illegal occupation by the
received no consideration so he was summarily removed from defendants were also correct and proper.
possession of the same. An action was brought by the plaintiff to
The Roman Catholic Church against the municipality of Placer
recover of the defendants the (1) value of certain articles taken from
(September 23, 1908): Court ruled that the property belonged to the
the church, and (2) the rental value of the church and its
Roman Catholic Church.
appurtenances, including the church cemetery from December 11,
1901 – April 1904. LC ruled in favor of the plaintiff. Barlin v Ramirez, Municipality of Ponce v Roman Catholic Apostolic
Church in Porto Rico
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 It is undoubted that the bishop of the diocese or the Roman Catholic
was located, or in the name of the Roman Catholic Apostolic Church, Apostolic Church itself is the real party in interest. The plaintiff
as the real party in interest); (2) The church had been erected by funds personally has no interest in the cause of action.
voluntarily contributed by the people of the municipality, and that the
articles within the church had been purchased with funds raised in like Sec. 114 of the Code of Civil Procedure: Every action must be
manner, therefore, the municipality was the owner thereof. prosecuted in the name of the real party in interest.
This Court has full power, apart from that power and authority which Formal substitution - Substitution so as to make the form express the
is inherent, to amend the process, pleadings, proceedings, and substance
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 No one is deceived for an instant as to whose interest are at stake.
convinced that we should do so. The form of its expression is alone defective.

Sec. 110 of the Code of Civil Procedure: Amendments in general. — Form is a method of speech used to express substance and make it
The court shall, in furtherance of justice, and on such terms, if any, as clearly appear. It is the means by which the substance reveals itself.
may be proper, allow a party to amend any pleading or proceeding If the form be faulty and still the substance shows plainly through no,
and at any stage of the action, in either the Court of First Instance or harm can come by making the form accurately expressive of the
the Supreme Court, by adding or striking out the name of any party, substance.
either plaintiff or defendant, or by correcting a mistake in the name of No one has been misled by the error in the name of the party plaintiff.
a party, or a mistaken or inadequate allegation or description in any If we should by reason of this error send this back for amendment and
other respect so that the actual merits of the controversy may speedily new trial, there would be on the retrial the same complaint, the same
be determined, without regard to technicalities, and in the most answer, the same defense, the same interests, the same witnesses,
expeditious, and inexpensive manner. The court may also, upon like and the same evidence. The name of the plaintiff would constitute the
terms, allow an answer or other pleading to be made after the time only difference between the old trial and the new. In our judgment
limited by the rules of the court for filing the same. Orders of the court there is not enough in a name to justify such action.
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 There is nothing sacred about processes or pleadings, their forms or
to be heard. contents. Their sole purpose is to facilitate the application of justice to
the rival claims of contending parties. They were created, not to hinder
Sec. 503: Judgment not to be reversed on technical grounds. — No and delay, but to facilitate and promote, the administration of justice.
judgment shall be reversed on formal or technical grounds, or for such The error in this case is purely technical. To take advantage of it for
error as has not prejudiced the real rights of the excepting party. other purposes than to cure it, does not appeal to a fair sense of
Such an amendment does not constitute a change in the identity of justice. Technicality, when it desserts its proper office as an aid to
the parties. justice and becomes its great hindrance and chief enemy, deserves
scant consideration from courts. There should be no pvested rights in
The plaintiff asserts in his complaint, and maintains that assertion all technicalities. No litigant should be permitted to challenge a record of
through the record, that he is engaged in the prosecution of this case, a court of these Islands for defect of form when his substantial rights
not for himself, but for the bishop of the diocese—not by his own right, have not been prejudiced thereby.
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 Judgment: Process, pleadings, proceedings and decision in this
litigation. He seeks only the welfare of the great church whose servant action is amended by substituting the Roman Catholic Apostolic
he is. Gladly permits his identity to be wholly swallowed up in that of Church in the place and stead of Alonso as party plaintiff. Decision of
his superior. the court below, so amended, is affirmed.