Mangaliag vs.

Catubig-Pastoral
G.R. NO. 143951, October 25, 2005
AUSTRIA-MARTINEZ, J.
DOCTRINE:
1. Lack of jurisdiction of a court may be raised at any stage of the proceedings, even on
appeal.

2. 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.

FACTS:
 Respondent Serquina filed a complaint for damages with the RTC against petitioners
Mangaliag and Solano alleging that the Serquina and his co-passengers sustained serious
injuries and permanent deformities from the collision of their tricycle with the
petitioners’ dump truck and the gross negligence, carelessness and imprudence of the
petitioners in driving the dump truck.
 Respondents seek damages in the form of medical expenses amounting to P71,392.00.
Respondents also claim P500,000.00 by way of moral damages, as a further result of his
hospitalization, lost income of P25,000.00 or the nominal damages, and attorney’s fees.
 After the respondent rested his case, petitioners testified in their defense. Subsequently,
petitioners filed a motion to dismiss on the ground of lack of jurisdiction over the subject
matter. They alleged that since the principal amount prayed for, in the amount of
P71,392.00, falls within the jurisdiction of MTC.
 Respondent opposed the motion saying that since the claim for damages is the main
action, the totality of the damages sought to be recovered should be considered in
determining jurisdiction and the petitioners’ defense of lack of jurisdiction has already
been barred by estoppel and laches. He contends that after actively taking part in the trial
proceedings and presenting a witness to seek exoneration, it would be unfair and legally
improper for petitioners to seek the dismissal of the case.
 RTC ruled in favor of respondent.
 Petitioners filed a Motion for Reconsideration which was denied.

ISSUES/RULINGS:
1. WON defense of lack of jurisdiction may be waived by estoppel through active participation
in the trial.

NO. In the present case, no judgment has yet been rendered by the RTC. As a matter of fact, as
soon as the petitioners discovered the alleged jurisdictional defect, they did not fail or neglect to
file the appropriate motion to dismiss. Hence, finding the pivotal element of laches to be absent,
the Sibonghanoy doctrine does not control the present controversy. Instead, the general rule
that the question of jurisdiction of a court may be raised at any stage of the proceedings
must apply. Therefore, petitioners are not estopped from questioning the jurisdiction of the
RTC.

2. Whether it is the amount of P71,392.00 as medical expenses, excluding moral, nominal

damages and attorney’s fees, which determines jurisdiction, hence it is MTC which has
jurisdiction.

NO. The well-entrenched principle is that the jurisdiction of the court over the subject matter of
the action is determined by the material allegations of the complaint and the law, irrespective of
whether or not the plaintiff is entitled to recover all or some of the claims or reliefs sought
therein. In the present case, the allegations in the complaint plainly show that private respondent
seeks to recover not only his medical expenses, lost income but also damages for physical
suffering and mental anguish due to permanent facial deformity from injuries sustained in the
vehicular accident. Viewed as an action for quasi-delict, the present case falls squarely within the
purview of Article 2219 (2),30 which provides for the payment of moral damages in cases of
quasi-delict causing physical injuries.
Private respondent’s claim for moral damages of ₱500,000.00 cannot be considered as merely
incidental to or a consequence of the claim for actual damages. It is a separate and distinct cause
of action or an independent actionable tort. It springs from the right of a person to the physical
integrity of his or her body, and if that integrity is violated, damages are due and assessable.
Hence, the demand for moral damages must be considered as a separate cause of action,
independent of the claim for actual damages and must be included in determining the
jurisdictional amount, in clear consonance with paragraph 2 of Administrative Circular No. 09-
94.

If the rule were otherwise, i.e., the court’s jurisdiction in a case of quasi-delict causing physical
injuries would only be based on the claim for actual damages and the complaint is filed in the
MTC, it can only award moral damages in an amount within its jurisdictional limitations, a
situation not intended by the framers of the law.