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PANTRANCO NORTH EXPRESS v. STANDARD INSURANCE COMPANY

FACTS:

On October 28, 1984, Crispin Gicale was driving his mother Martina Gicale's passenger jeepney in Talavera, Nueva Ecija. The jeepney was followed by a passenger bus owned by Pantranco North Express, Inc. and driven by Alexander Buncan. During a curve on the National Highway, the bus overtook the jeepney and collided with its left rear side before quickly driving away. Crispin reported the incident to the Talavera Police Station and to Standard Insurance Company, Inc., the insurer of the jeepney. The repairs for the damages incurred by the collision cost a total of P21,415.00. However, Standard Insurance only paid P8,000.00, leaving Martina Gicale with a balance of P13,415.00. Both Standard Insurance and Martina demanded reimbursement from Pantranco and Alexander Buncan, but they refused. Consequently, Standard Insurance and Martina filed a complaint for sum of money against Pantranco and Alexander Buncan before the Regional Trial Court (RTC) in Manila. The trial court ruled in favor of Standard Insurance and Martina, prompting Pantranco and Alexander Buncan to appeal the decision to the Court of Appeals. Their appeal was denied, leading to their petition for review on certiorari before the Supreme Court.

ISSUES:

  1. Whether or not the trial court has jurisdiction over the subject of the action.

  2. Whether or not petitioners are liable to respondents.

  3. Whether or not petitioners were deprived of their right to due process.

RULING:

  1. The Court of Appeals ruled that the trial court has jurisdiction over the subject of the action. The total of the two claims, which is P21,415, is more than the jurisdictional amount of the Regional Trial Court, which is P20,000.

  2. The Court of Appeals affirmed the trial court's ruling that petitioners are liable to respondents. The evidence preponderantly established their liability for quasi-delict under Article 2176 of the Civil Code.

  3. The Court of Appeals ruled that petitioners were not deprived of their right to due process. The court did not declare them in default because they failed to present evidence during the scheduled hearing. They had the opportunity to present their evidence but failed to do so.

PRINCIPLES:

  • The Totality Rule under Section 19, Batas Pambansa Bilang 129 states that the sum of the claims determines the jurisdictional amount of the court.

  • Misjoinder of parties does not affect the jurisdiction of the court nor is it a ground to dismiss the complaint.

  • When a case is deemed submitted for decision, it means that the parties are deemed to have waived their right to present evidence if they fail to do so.