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(4) stipulated that any discovery conducted during the pendency of these Third, the trial court ascribed little significance to the voluntary
actions may be used in any foreign proceeding to the same extent as if it had appearance of the defendant companies.
been conducted in proceedings initiated there; and
Fourth, the RTC of General Santos City ruled that the act of NAVIDA,
(5) submitted an agreement binding them to satisfy any final judgment rendered
et al., of filing the case in the Philippine courts violated the rules on forum
in favor of plaintiffs by a foreign court.
shopping and litis pendencia.
In the event that the highest court of any foreign country finally affirms
the dismissal for lack of jurisdiction of an action commenced by a plaintiff in RTC of General Santos City declared that it had already lost its
these actions in his home country or the country in which he was injured, that jurisdiction over the case. Hence, this petition for review.
plaintiff may return to this court and, upon proper motion, the court will resume
jurisdiction over the action as if the case had never been dismissed for. Civil Case No. 24,251-96 before the RTC of Davao City and G.R. Nos.
126654, 127856, and 128398
Civil Case No. 5617 before the RTC of General Santos City and G.R. Nos.
125078 and 125598 Another joint complaint for damages against SHELL, DOW,
OCCIDENTAL, DOLE, DEL MONTE, and CHIQUITA was filed before Branch 16
A total of 336 plaintiffs from General Santos City filed a Joint of the RTC of Davao City by 155 plaintiffs from Davao City. They alleged that
Complaint in the RTC of General Santos City on August 10, 1995. Named as as workers in the banana plantation and/or as residents near the said plantation,
defendants therein were: Shell Oil Co. (SHELL); Dow Chemical Co. (DOW); they were made to use and/or were exposed to nematocides, which contained
Occidental Chemical Corp. (OCCIDENTAL); Dole Food Co., Inc., Dole Fresh the chemical DBCP. According to ABELLA, et al., such exposure resulted in
“serious and permanent injuries to their health, including, but not limited to, The allegations of the plaintiffs in the complaints constitute the cause of
sterility and severe injuries to their reproductive capacities.” action of plaintiff claimants a quasi-delict, which under the Civil Code is defined
as an act, or omission which causes damage to another, there being fault or
The RTC of Davao City, however, junked Civil Cases. Hence, this negligence.
petition.
Clearly then, the acts and/or omissions attributed to the defendant
companies constitute a quasi-delict which is the basis for the claim for damages
ISSUE: filed by NAVIDA, et al., and ABELLA, et al., with individual claims of
WON the RTC of Gensan and Davao have jurisdiction over the approximately P2.7 million for each plaintiff claimant, which obviously falls
case? within the purview of the civil action jurisdiction of the RTCs.
In all other cases in which the demand, exclusive of interest, damages In a very real sense, most of the evidence required to prove the claims
of whatever kind, attorney’s fees, litigation expenses, and costs or the value of of NAVIDA, et al., and ABELLA, et al., are available only in the Philippines.
the property in controversy exceeds One hundred thousand pesos First, plaintiff claimants are all residents of the Philippines, either in General
(P100,000.00) or, in such other cases in Metro Manila, where the demand, Santos City or in Davao City. Second, the specific areas where they were
exclusive of the abovementioned items exceeds Two hundred thousand pesos allegedly exposed to the chemical DBCP are within the territorial jurisdiction of
(P200,000.00). the courts a quo wherein NAVIDA, et al., and ABELLA, et al., initially filed their
claims for damages. Third, the testimonial and documentary evidence from
Supreme Court Administrative Circular No. 09-94, states: important witnesses, such as doctors, co-workers, family members and other
The exclusion of the term “damages of whatever kind” in determining the members of the community, would be easier to gather in the Philippines.
jurisdictional amount under Section 19 (8) and Section 33 (1) of B.P. Blg. 129,
as amended by R.A. No. 7691, applies to cases where the damages are merely SHORTER VERSION:
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 Navida v. Dizon
of action, the amount of such claim shall be considered in determining the A number of personal injury suits were filed in different Texas state
jurisdiction of the court. courts by citizens of twelve foreign countries, including the Philippines.
The thousands of plaintiffs sought damages for injuries they allegedly
It is clear that the claim for damages is the main cause of action and sustained from their exposure to DBCP, while working on farms in 23
that the total amount sought in the complaints is approximately P2.7 million for foreign countries.
each of the plaintiff claimants. The RTCs unmistakably have jurisdiction over the ISSUE: W/N the RTC of Gen Santos City and the RTC of Davao City
cases filed in General Santos City and Davao City. had jurisdiction over the present complaint? YES
SC: The rule is settled that jurisdiction over the subject matter of a case distribution through sale or other disposition, resulting in their becoming part
is conferred by law and is determined by the allegations in the
of the stream of commerce,” and, hence, outside the jurisdiction of the RTCs.
complaint and the character of the relief sought, irrespective of whether
the plaintiffs are entitled to all or some of the claims asserted therein.
Once vested by law, on a particular court or body, the jurisdiction over
the subject matter or nature of the action cannot be dislodged by
anybody other than by legislature through the enactment of a law.
From the foregoing, it is clear that the claim for damages is the main
cause of action and that the total amount sought in the complaint is
approx P2.7M for each of plaintiff claimants. The RTCs unmistakably
have jurisdiction over the cases filed.
The allegations in the complaint constitute the cause of action of
plaintiffs – a quasi-delict, which under the NCC, is defined as an act, or
omission which causes damage to another, there being fault or
negligence.
Same; Same; Same; Conflict of Laws; Where the factual allegations in the
Amended Joint-Complaints all point to their cause of action, which undeniably
occurred in the Philippines, it is error on the part of the courts a quo to dismiss
the cases on the ground of lack of jurisdiction on the mistaken assumption that
the cause of action narrated by the plaintiffs took place abroad and had
occurred outside and beyond the territorial boundaries of the Philippines, i.e.,
“the manufacture of the pesticides, their packaging in containers, their
distribution through sale or other disposition, resulting in their becoming part
of the stream of commerce.”—Moreover, the injuries and illnesses, which
NAVIDA, et al., and ABELLA, et al., allegedly suffered resulted from their
exposure to DBCP while they were employed in the banana plantations located
in the Philippines or while they were residing within the agricultural areas also
located in the Philippines. The factual allegations in the Amended Joint-
Complaints all point to their cause of action, which undeniably occurred in the
Philippines. The RTC of General Santos City and the RTC of Davao City
obviously have reasonable basis to assume jurisdiction over the cases. It is,
therefore, error on the part of the courts a quo when they dismissed the cases
on the ground of lack of jurisdiction on the mistaken assumption that the cause
of action narrated by NAVIDA, et al., and ABELLA, et al., took place abroad and
had occurred outside and beyond the territorial boundaries of the Philippines,
i.e., “the manufacture of the pesticides, their packaging in containers, their