Posted by: Riyani Marie M. Nartea on July 26, 2018
FACTS:
On 30 May 2003, Elmer F. Gomez filed a Complaint with the RTC for a sum of money, damages and payment of attorney's fees against Ma. Lita Montalban. The Complaint alleged that on August 26, 1998, Montalban obtained a loan from Gomez in the sum of ₱40,000.00 with a voluntary proposal on her part to pay 15% interest per month. Upon receipt of the proceeds of the loan, Montalban issued in favor of Gomez, as security, a postdated check in the sum of ₱46,000.00, covering the ₱40,000.00 principal loan amount and ₱6,000.00 interest charges for one month. When the check became due, respondent Montalban to pay the loan despite several demands. Thus Gomez filed the Complaint praying for the payment of ₱238,000.00, representing the principal loan and interest charges, plus 25% of the amount to be awarded as attorney's fees, as well as the cost of suit. Montalban contends that the RTC has no jurisdiction because the principal amount of the loan is only P40,000.00 and that the interest should not be included in determination of jurisdiction.
ISSUE:
Whether or not the Regional Trial Court has jurisdiction over this case for sum of money, damages and attorney's fees where the principal amount of the obligation is ₱40,000.00 but the amount of the demand per allegation of the complaint is ₱238,000.00.
HELD:
Yes.
The Court gleans from the foregoing that petitioner's cause of action is the respondent's violation of their loan agreement. In that loan agreement, respondent expressly agreed to pay the principal amount of the loan, plus 15% monthly interest. Consequently, petitioner is claiming and praying for in his Complaint the total amount of ₱238,000.00, already inclusive of the interest on the loan which had accrued from 1998. Since the interest on the loan is a primary and inseparable component of the cause of action, not merely incidental thereto, and already determinable at the time of filing of the Complaint, it must be included in the determination of which court has the jurisdiction over petitioner's case. Using as basis the ₱238,000.00 amount being claimed by petitioner from respondent for payment of the principal loan and interest, this Court finds that it is well within the jurisdictional amount fixed by law for RTCs. There can be no doubt that the RTC in this case has jurisdiction to entertain, try, and decide the petitioner's Complaint.
To this Court, it is irrelevant that during the course of the trial, it was proven that respondent is only liable to petitioner for the amount of ₱40,000.00 representing the principal amount of the loan; ₱57,000.00 as interest thereon at the rate of 24% per annum reckoned from 26 August 1998 until the present; and ₱15,000.00 as attorney's fees. Contrary to respondent's contention, jurisdiction can neither be made to depend on the amount ultimately substantiated in the course of the trial or proceedings nor be affected by proof showing that the claimant is entitled to recover a sum in excess of the jurisdictional amount fixed by law. Jurisdiction is determined by the cause of action as alleged in the complaint and not by the amount ultimately substantiated and awarded.
Basic as a hornbook principle is that jurisdiction over the subject matter of a case is conferred by law and determined by the allegations in the complaint which comprise a concise statement of the ultimate facts constituting the plaintiff's cause of action. The nature of an action, as well as which court or body has jurisdiction over it, is determined based on the allegations contained in the complaint of the plaintiff, irrespective of whether or not the plaintiff is entitled to recover upon all or some of the claims asserted therein. The averments in the complaint and the character of the relief sought are the ones to be consulted. Once vested by the allegations in the complaint, jurisdiction also remains vested irrespective of whether or not the plaintiff is entitled to recover upon all or some of the claims asserted therein.
FACTS:
On 30 May 2003, Elmer F. Gomez filed a Complaint with the RTC for a sum of money, damages and payment of attorney's fees against Ma. Lita Montalban. The Complaint alleged that on August 26, 1998, Montalban obtained a loan from Gomez in the sum of ₱40,000.00 with a voluntary proposal on her part to pay 15% interest per month. Upon receipt of the proceeds of the loan, Montalban issued in favor of Gomez, as security, a postdated check in the sum of ₱46,000.00, covering the ₱40,000.00 principal loan amount and ₱6,000.00 interest charges for one month. When the check became due, respondent Montalban to pay the loan despite several demands. Thus Gomez filed the Complaint praying for the payment of ₱238,000.00, representing the principal loan and interest charges, plus 25% of the amount to be awarded as attorney's fees, as well as the cost of suit. Montalban contends that the RTC has no jurisdiction because the principal amount of the loan is only P40,000.00 and that the interest should not be included in determination of jurisdiction.
ISSUE:
Whether or not the Regional Trial Court has jurisdiction over this case for sum of money, damages and attorney's fees where the principal amount of the obligation is ₱40,000.00 but the amount of the demand per allegation of the complaint is ₱238,000.00.
HELD:
Yes.
The Court gleans from the foregoing that petitioner's cause of action is the respondent's violation of their loan agreement. In that loan agreement, respondent expressly agreed to pay the principal amount of the loan, plus 15% monthly interest. Consequently, petitioner is claiming and praying for in his Complaint the total amount of ₱238,000.00, already inclusive of the interest on the loan which had accrued from 1998. Since the interest on the loan is a primary and inseparable component of the cause of action, not merely incidental thereto, and already determinable at the time of filing of the Complaint, it must be included in the determination of which court has the jurisdiction over petitioner's case. Using as basis the ₱238,000.00 amount being claimed by petitioner from respondent for payment of the principal loan and interest, this Court finds that it is well within the jurisdictional amount fixed by law for RTCs. There can be no doubt that the RTC in this case has jurisdiction to entertain, try, and decide the petitioner's Complaint.
To this Court, it is irrelevant that during the course of the trial, it was proven that respondent is only liable to petitioner for the amount of ₱40,000.00 representing the principal amount of the loan; ₱57,000.00 as interest thereon at the rate of 24% per annum reckoned from 26 August 1998 until the present; and ₱15,000.00 as attorney's fees. Contrary to respondent's contention, jurisdiction can neither be made to depend on the amount ultimately substantiated in the course of the trial or proceedings nor be affected by proof showing that the claimant is entitled to recover a sum in excess of the jurisdictional amount fixed by law. Jurisdiction is determined by the cause of action as alleged in the complaint and not by the amount ultimately substantiated and awarded.
Basic as a hornbook principle is that jurisdiction over the subject matter of a case is conferred by law and determined by the allegations in the complaint which comprise a concise statement of the ultimate facts constituting the plaintiff's cause of action. The nature of an action, as well as which court or body has jurisdiction over it, is determined based on the allegations contained in the complaint of the plaintiff, irrespective of whether or not the plaintiff is entitled to recover upon all or some of the claims asserted therein. The averments in the complaint and the character of the relief sought are the ones to be consulted. Once vested by the allegations in the complaint, jurisdiction also remains vested irrespective of whether or not the plaintiff is entitled to recover upon all or some of the claims asserted therein.
