4. Ratilla v.

Tapucar

G.R. No. L-45018 / January 24, 1977

Principle/s:

1. Where there are several claims between the same parties embodied in the same complaint, the
totality of the claims supplies the jurisdictional test. The damages are included in the amount of
the demand used as basis for determining the court’s jurisdiction.
2. CFI shall have original jurisdiction in all cases in which the demand, exclusive of interest, or the
value of the property in controversy, amounts to more than Php 10,000.00

Facts:

1. Alegandro V. Ratilla filed a collection suit in the Court of First Instance in Agusan del Norte,
Butuan City Branch 1 against Floresita Jamora. (March 6, 1975)
2. He prayed that Jamora pay him the sum of: Php 13,350
a. Php 5,350 (Balance of the price of two freezers, plus interest)
b. Php 2,000 (attorney’s fees)
c. Php 3,000 (Moral Damages)
d. Php 2,000 (exemplary damages)
e. Php 1,000 (litigation expenses)
3. Jamora in her answer prayed for the dismissal of the complaint and interposed a counterclaim
for Php 15,000 as actual damages, attorney’s fees and moral damages.
4. In the pre-trial, CFI dismissed the case for lack of jurisdiction, reasoning out that since the
principal claim of Ratilla amounted only to Php 5,350, it is within the exclusive jurisdiction of the
inferioir courts, and that the damages were included so that the case would come within the
jurisdiction of the CFI. (September 15, 1976)
5. Ratilla filed a Motion for Reconsideration which was denied. (October 4, 1976)
6. Appealed the case to the SC by filing a petition for certiorari and mandamus (October 21, 1976)
7. Mrs. Jamora answered the petition.

Argument of Ratilla:

Argument of Jamora:

1. Prayed for the dismissal of the complaint because Ratilla’s claim had beed
extinguished due to the surrender of one freezer and the destruction of the other
freezer.
2. Ratilla’s purpose in inflating the claim, by adding damages, was to enable him to file
his complaint in Butuan city instead of in Bislig, Surigao del sur where she is a
resident.
3. She further alleges that Ratilla resorted to the same maneuver in Civil Cases 1742
and 1743, which he filed against two other residents of Bislig.
Issue/s:

W/N the trial court erred in dismissing Ratilla’s collection action against Mrs. Jamora

Ruling:

Yes.

It is clear under the law that where there are several claims between the same parties
embodied in the same complaint, the totality of the claims supplies the jurisdictional test. The damages
are included in the amount of the demand used as basis for determining the court’s jurisdiction.

Since the total demand is Php 13,350, which exceed Php 10,000, the case falls within the
original, exclusive jurisdiction of the CFI.