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D 24. Movers-Basco Integrated Port Services Inc, v. Cyborg Leasing Corp. 317 Scra 327

This case involves a dispute over a leased forklift. Cyborg Leasing Corporation filed a complaint in the Metropolitan Trial Court against Conpac Warehousing and Movers-Baseco Integrated Port Services regarding unpaid rent and seizure of the forklift. The total amount claimed in the complaint, including unpaid rent, damages, and fees, exceeded the MTC's jurisdiction. The MTC dismissed the case for lack of jurisdiction. The Supreme Court upheld the dismissal, finding that the unpaid rent was not merely incidental and the total amount exceeded the MTC's jurisdiction, so the case was not properly filed in the MTC.

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324 views3 pages

D 24. Movers-Basco Integrated Port Services Inc, v. Cyborg Leasing Corp. 317 Scra 327

This case involves a dispute over a leased forklift. Cyborg Leasing Corporation filed a complaint in the Metropolitan Trial Court against Conpac Warehousing and Movers-Baseco Integrated Port Services regarding unpaid rent and seizure of the forklift. The total amount claimed in the complaint, including unpaid rent, damages, and fees, exceeded the MTC's jurisdiction. The MTC dismissed the case for lack of jurisdiction. The Supreme Court upheld the dismissal, finding that the unpaid rent was not merely incidental and the total amount exceeded the MTC's jurisdiction, so the case was not properly filed in the MTC.

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Sarah Jade Layug
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© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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Movers-Baseco Integrated Port Services, Inc. vs.

Cyborg Leasing
Corporation, G.R. No. 131755. October 25, 1999.

FACTS

Cyborg Leasing Corporation (“Cyborg”), herein private respondent, filed a case,


captioned “Damages with Prayer for a Writ of Replevin” against Conpac
Warehousing, Inc. (“Conpac”), and herein petitioner Movers-Baseco Integrated Port
Services (“Movers”). The complaint alleged that pursuant to a lease agreement,
Cyborg had delivered one (1) NISSAN forklift to CONPAC. Conpac supposedly failed
and refused to pay the stipulated rentals of P11, 000.00 starting April 1995
notwithstanding demands therefor. Sometime in May 1995, petitioner Movers-
Baseco took control of the operations of Conpac and seized all cargoes and
equipment including the subject forklift. Petitioner ignored Cyborg’s demand for the
return to it of the equipment and the formal disclaimer of ownership made by
CONPAC.

Upon application of Cyborg, a writ of replevin was issued following the filing of a
P300,000.00 replevin bond. Petitioner was served with a copy of the summons and
the writ of replevin. On 14 February 1997, petitioner filed a motion to dismiss the
case on the ground of lack of jurisdiction on the part of the MTC since the complaint
had asked for, among other things, the following:

(a) x x x actual market value of the equipment (par. 8 of the


complaint)..............................................P150,000.00

(b) x x x actual damages for use of the equipment at the rate of P11,000.00
monthly from 09 April 1995 up to the time possession was taken by the
plaintiff under the order of the Honorable Court (par. 9[a] of the
complaint)................................................242,000.00

(c) exemplary damages ..................................1,000,000.00

(d) attorney’s fees...........................................50,000.00

Total............................................................................P1,442,000.00

MTC dismissed the complaint for lack of jurisdiction. Upon the MTC’s denial of
Cyborg’s motion for reconsideration, Cyborg caused the filing of the instant petition.

In its motion to dismiss before the MTC Manila, Movers-Baseco argued that the MTC
had no jurisdiction over this case because while the alleged amount of the forklift is
P150, 000, together with the other amounts/damages claimed, the total is beyond
the MTC’s jurisdiction.

Cyborg argued that since the principal action is for replevin, the other amounts
being merely incidental, as the amount of P150,000 is within the MTC jurisdiction,
the latter is competent to take cognizance of the case.

ISSUE

Whether or not the complaint filed by Cyborg is within the jurisdiction of the MTC.

HELD

It is not within the jurisdiction of the MTC, therefore the MTC correctly dismissed
the case on the ground of lack of jurisdiction.

Cyborg relied on Section 33 of Batas Pambansa Blg. 129, as amended by Republic


Act No. 7691, which states:

“SEC. 33. Jurisdiction of Metropolitan Trial Courts; Municipal Trial Courts and
Municipal Circuit Trial Courts in Civil Cases.—Metropolitan Trial Courts, Municipal
Trial Courts, and Municipal Circuit Trial Courts shall exercise:

“(1) Exclusive original jurisdiction over civil actions and probate proceedings
testate and intestate, including the grant of provisional remedies in proper
cases, where the value of the personal property, estate, or amount of the
demand does not exceed One hundred thousand pesos (P100,000.00) or, in
Metro Manila where such personal property, estate, or amount of the
demand does not exceed Two hundred thousand pesos (P200,000.00),
exclusive of interest, damages of whatever kind, attorney’s fees, litigation
expenses, and costs, the amount of which must be specifically alleged:
Provided, That interest, damages of whatever kind, attorney’s fees, litigation
expenses, and costs shall be included in the determination of the filing fees:
Provided, further, That where there are several claims or causes of actions
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”;

Supreme Court Administrative Circular No. 09-94, in turn, provides:

“SUBJECT: Guidelines in the Implementation of Republic Act No. 7691,


Entitled ‘An Act Expanding the Jurisdiction of the Metropolitan Trial Courts,
Municipal Trial Courts and Municipal Circuit Trial Courts, Amending For the
Purpose Batas Pambansa Blg. 129, otherwise Known As the ‘Judiciary
Reorganization Act of 1980.’

“x x x         x x x         x x x
“2. the exclusion of the term ‘damages’ of whatever kind in determining the
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 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 of action, the amount of such claim shall be
considered in determining the jurisdiction of the court.”

The complaint filed by Cyborg with the Metropolitan Trial Court of Manila prayed for
the return of the Nissan Forklift to it, as owner and as lessor pursuant to a lease
agreement executed by it in favor of Conpac, or, in the alternative for the payment
of P150,000.00 (the actual market value of the forklift), plus damages, plus the
amount of unpaid lease, starting 09 April 1995 at P11,000.00 per month, which as
of the time of the filing of the complaint on 22 August 1996 had amounted to
P180,000.00 which, together with the value of the forklift, reach the sum of
P230,000.00 excluding the amount of damages and attorney’s fees likewise
claimed. It would be incorrect to argue that the actual damages in the form of
unpaid rentals were just incident of the action for the return of the forklift,
considering that private respondent specifically sought in the complaint not only the
seizure of the forklift from petitioner-Movers, which took control of the operations
of Conpac, but likewise the payment of unpaid and outstanding rentals. Verily, the
Metropolitan Trial Court’s orders of 18 March 1997 and 10 June 1997 dismissing the
complaint and denying the motion of private respondent, respectively, were
properly decreed.

The RTC acted on the mistaken notion that the 1997 Rules of Civil Procedure took
effect only in October 1997; in fact, the new rules became operative since 01 July
1997. Therefore, the amount of the complaint is indicative that the case is not
within the jurisdiction of the MTC, hence, should be denied.

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