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ARACELI J. CABRERA v. ANGELA G. FRANCISCO

FACTS:

Respondents' father executed a document appointing Severino Cabrera as administrator of his real properties. When Severino died, Araceli and Arnel, with respondents' consent, took over the administration of the properties. They were promised a commission of five percent of the total purchase price if they were able to find buyers for the properties. Petitioners introduced a real estate broker to respondents, but a conflict arose when respondents appointed the broker as the new administrator and terminated Araceli and Arnel's services. Petitioners demanded their commission but to no avail, so they filed a Complaint for Collection of Agent's Compensation, Commission, and Damages. The RTC granted respondents' Motion to Dismiss and dismissed the Complaint for lack of jurisdiction, failure to state a cause of action, and lack of legal capacity of Araceli and Arnel to sue on behalf of the other heirs of Severino. The CA affirmed the RTC's ruling and denied petitioners' Motion for Reconsideration. Petitioners filed a Petition for Review on Certiorari before the Supreme Court.

ISSUES:

  1. Whether the RTC made an independent assessment of the merits of respondents' Motion to Dismiss.

  2. Whether the RTC has jurisdiction over petitioners' Complaint.

  3. Whether the action filed by the petitioners is capable of pecuniary estimation.

  4. Whether the action involves an interest in real property.

  5. Whether the RTC has jurisdiction over petitioners' Complaint.

  6. Whether the claim for moral damages should be included in the computation of the total claims.

  7. Whether or not the Complaint states a cause of action.

  8. Whether or not Araceli and Arnel have authority to sue in behalf of the other heirs of Severino.

RULING:

  1. The RTC made an independent assessment of the merits of respondents' Motion to Dismiss as it judiciously examined the Complaint, the documents attached thereto, and the other pleadings filed in connection with the said motion. The RTC made its own observations and conclusions in resolving the motion. Therefore, the claim that the RTC merely adopted the arguments of respondents in their Motion to Dismiss is without merit.

  2. The RTC does not have jurisdiction over petitioners' Complaint. The Complaint neither involves a subject matter incapable of pecuniary estimation nor interest in a real property the assessed value of which exceeds P200,000.00. The jurisdiction of the court is determined by the nature of the action pleaded and the relief sought in the Complaint, and based on the pertinent portions of the Complaint, the RTC does not have jurisdiction over the case.

  3. The action filed by the petitioners is capable of pecuniary estimation. The main purpose of the complaint is to collect the commission and compensation allegedly promised by the respondents. The payment of such money claim is the principal relief sought and not merely incidental to or a consequence of another action where the subject of litigation may not be estimated in terms of money.

  4. The action does not involve an interest in real property. The letter confirming Severino's appointment as administrator did not provide for compensation in the form of real estate. The allegation in the complaint is that the commission promised to the petitioners would be equivalent to five percent of the total purchase price of the properties.

  5. The RTC does not have jurisdiction over petitioners' Complaint. The jurisdictional amount for RTCs outside of Metro Manila is P200,000.00. The demand in petitioners' Complaint did not exceed this amount.

  6. The claim for moral damages should not be included in the computation of the total claims. Under Section 19(8) of BP 129, the jurisdictional amount is exclusive of damages of whatever kind. The claim for moral damages is merely incidental to the main cause of action and cannot be included in determining the jurisdictional amount.

  7. The Petition for Review on Certiorari is denied. The Court affirms the Decision of the Court of Appeals, holding that the Complaint states no cause of action and that Araceli and Arnel have no authority to sue in behalf of the other heirs of Severino.

PRINCIPLES:

  • It is the court's duty to independently assess the merits of a motion. (Stated by the court)

  • The jurisdiction of the court is determined by the nature of the action pleaded as appearing from the allegations in the Complaint. (Stated by the court)

  • In determining whether an action is capable of pecuniary estimation, the court considers the nature of the principal action or remedy sought. If it is primarily for the recovery of a sum of money, the action is considered capable of pecuniary estimation.

  • When the basic issue is something other than the right to recover a sum of money and the money claim is purely incidental to or a consequence of the principal relief sought, the action is considered not capable of pecuniary estimation.

  • An action involving an interest in real property requires that the relief sought be directly related to the real property. The mere mention of real property in an action does not automatically make it an action involving an interest in real property.

  • A real action is an action affecting title to or possession of real property, or interest therein. It includes partition or condemnation of, or foreclosure of mortgage on, real property. (Section 1, Rule 4 of the Rules of Court)

  • The jurisdictional amount for RTCs outside of Metro Manila is P200,000.00, while for cases in Metro Manila, it is P400,000.00. (Section 19(8) of BP 129, as amended by RA 7691)

  • The jurisdictional amount is the amount that exceeds the demand or claim exclusive of interests, damages of whatever kind, attorney's fees, litigation expenses, and costs, or the value of the property. (Section 19(8) of BP 129)

  • Damages of whatever kind are excluded in determining the jurisdictional amount, except when the claim for damages is the main cause of action or one of the causes of action. (Administrative Circular No. 09-94)

  • Parties are generally bound by the issues they have raised in the lower courts and are precluded from raising new issues on appeal.

  • Matters which were not raised in the motion for reconsideration before the appellate court cannot be raised for the first time in the Supreme Court.