FLORES v.

MALLARE-PHILLIPS
24 Sept 1986
TOPIC IN SYLLABUS: Cause of Action; Joinder

G.R. No. 66620

Feria, J.

SUMMARY: Flores filed a case before the RTC against Binongcal for P11,643.00 and Calion for P10,212.00. RTC
dismissed for lack of jurisdiction, saying below jurisdictional amount of P20K. Flores appealed, claiming joinder of
defendants. SC denies, saying misjoinder as the claims against Binongcal and Calion are separate and distinct from
each other and neither falls within jurisdictional amount of RTC. SC also compares old and new rules of joinder of
parties. Under the old rules (wrt to joinder of defendants), jurisdiction is acquired if based on the amount of each claim
sought to be joined (regardless of w/n same transactions). Under the new rules, the totality test is applied, and joinder is
only allowed if the causes of action arise out of the same transaction or series of transactions, and there is a common
question of law or fact.
FACTS:
Flores filed a case before the RTC of Baguio City and Benguet Province:
1. against Ignacio Binongcal for refusing to pay P11,643.00 representing the cost of truck tires the latter purchased
on credit from Flores from August to October 1981
2. against Fernando Calion for refusing to pay P10,212.00 representing the cost of truck tires the latter purchased on
credit from Flores from March 1981 to October 1981.
Binongcals counsel filed a Motion to Dismiss on the ground of lack of jurisdiction.
o Amount of the demand against Binongcal was only P11,643.00
o Under BP 29, RTC only has exclusive original jurisdiction if demand is more than P20,000.00.
o Although Calion was also impleaded, his obligation for P10,212.00 is separate and distinct.
o Callions counsel joined in the Motion.
RTC judge (Mallare-Phillipps) granted the Motion and dismissed petitioners complaint. SC affirms
ISSUE: W/N RTC had jurisdiction? NO.
PETITIONERS ARGUMENT: Apply the totality rule under Sec. 33(1) of BP 129:
where there are several claims or causes of action between the same or different parties, embodied in the
same complaint, the amount of the demand shall be the totality of the claims in all the causes of action,
irrespective of whether the causes of action arose out of the same or different transactions
Sec 11, of Interim Rules, also provide:
In actions where the jurisdiction of the court is dependent on the amount involved, the test of jurisdiction shall be
the aggregate sum of all the money demands, exclusive only of interest and costs, irrespective of whether or not
the separate claims are owned by or due to different parties. If any demand is for damages in a civil action, the
amount thereof must be specifically alleged.
1
Comparing these to Sec. 88 of the Judiciary Act of 1948 , the deletion of the last phrase made the totality of claims in all,
not in each, of the causes of action, as the jurisdictional test.
HELD:
No difference between the old and new rules with respect to the fact that when a plaintiff sues a defendant on two or
more separate causes of action, the amount of demand shall be the totality of all claims in all the causes of action
(w/n same transactions).
However there is a difference wrt two or more plaintiffs having separate causes of action against a defendant.
o OLD RULE: "where the claims or causes of action joined in a single complaint are separately owned by or due to
different parties, each separate claim shall furnish the jurisdictional test";
o NEW RULE: same as with one plaintiff against two or more defendants.
But, Rule 3, Sec. 6 states that these causes of action should arise out of the same transaction or series of
transactions and there should be a common question of law or fact.
In this case, there is a misjoinder of parties because Binongcals and Calions claims are separate and distinct from
each other; and neither of their claims falls within the RTC jurisdiction for being less than P20K
*SC also illustrated the difference of the old and new rules of permissive joinders via these cases. If the new rules were applied in here, the
RTC would have jurisdiction only if claims arose from same transactions / series of transactions; and there is a common question of law or fact.

Soriano y Cia v. Jose: 29 employees joined in a complaint against defendant to collect their respective claims. Each of the 29 claims fall
under the municipal court, but its aggregate sum would fall under RTC. In this case, even if demands were separate, distinct and
independent, joint suit was taken cognizance by the municipal courts.

International Colleges v. Argonza: 25 dismissed teachers jointly sued defendant for unpaid salaries, SC affirmed the jurisdiction of the
municipal court because the amount of each claim was within the jurisdiction of the municipal courts.

1 Where there are several claims or causes of action between the same parties embodied in the same complaint, the amount of the demand shall be the totality of
the demand in all the causes of action, irrespective of whether the causes of action arose out of the same or different transactions; but where the claims or causes
of action joined in a single complaint are separately owned by or due to different parties, each separate claim shall furnish the jurisdictional test

CASE 03