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Iniego vs Purganan
March 24, 2006. G.R. No. 166876
Private respondent Fokker Santos filed a complaint for quasi-delict and damages against Jimmy T. Pinion and petitioner Artemio Iniego, stemming from a vehicular accident wherein Pinion was the driver of a freight truck that hit respondent’s jitney, while petitioner was the owner of the truck and employer of Pinion. Later, after private respondent filed a motion to declare petitioner in default for his failure to answer the complaint, the latter filed a Motion to Admit and a Motion to Dismiss the complaint on the grounds that the RTC has no jurisdiction over the cause of action of the case. Subsequently respondent Judge Guillermo G. Purganan of the Manila RTC denied petitioner’s motion to Dismiss, ruling that the main cause of action is not the claim for damages but quasi-delict. Damages are claimed only as a result of the alleged fault or negligence of the petitioner under Article 2180 of the Civil Code. Since quasi-delicts could not be the subject of pecuniary estimation, the RTC has exclusive jurisdiction. After his motion for reconsideration was denied by the RTC, the petitioner filed a petition for certiorari with the CA, which was denied due to lack of merit. In his current petition for review, petitioner contends that actions for damages based on quasi-delict are capable of pecuniary estimation; hence, jurisdiction falls upon either the municipal courts, or the RTCs, depending on the value of the damages claimed.
Whether or not actions for damages based on quasi-delict is capable of pecuniary estimation.
Yes. Petition for Certiorari denied for lack of merit. Fault or negligence is not actionable by itself, and must be a resulting damage to a third person. The relief available to the offended party in such cases is for the reparation, restitution, or payment of such damage. The fault or negligence of the defendant, is inextricably intertwined with the claim for damages, and there can be no action based on quasi-delict without a claim for damages. The subject matter of actions for damages based on quasi-delict is capable of pecuniary estimation. In the current case, the total amount of damages claimed by the private respondent still exceeds the jurisdictional limit of P400,000.00, and thus remains under the jurisdiction of the RTC. Furthermore, Rule 2, Section 5 allows a party to assert as many causes of action as he may have against the opposing party, while subsection (d) provides that where the claims in all such joined causes of action are principally for recovery of money, the aggregate amount claimed shall be the test of jurisdiction. Whether or not the different claims for damages are based on a single cause of action or different causes of action, it is the total amount thereof which shall govern.