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    Flores V Mallere-Philipp 144 SCRA 377

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    Vic Rabaya
    (1) Flores sued Binongcal and Calion separately in the RTC to collect debts for truck tires purchased on credit. Binongcal's debt was P11,643 while Calion's was P10,212. (2) Binongcal argued the RTC lacked jurisdiction over the case against him alone, as the amount was below the RTC's threshold of P20,000. However, the RTC ruled it had jurisdiction when considering the total debt (P11,643 + P10,212). (3) The Supreme Court affirmed, noting that under the new totality rule, separate claims against different defendants can be aggregated to determine jurisdiction, as long as the claims arise from the same transaction

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    Flores V Mallere-Philipp 144 SCRA 377

    Uploaded by

    Vic Rabaya
    516 views2 pages
    (1) Flores sued Binongcal and Calion separately in the RTC to collect debts for truck tires purchased on credit. Binongcal's debt was P11,643 while Calion's was P10,212. (2) Binongcal argued the RTC lacked jurisdiction over the case against him alone, as the amount was below the RTC's threshold of P20,000. However, the RTC ruled it had jurisdiction when considering the total debt (P11,643 + P10,212). (3) The Supreme Court affirmed, noting that under the new totality rule, separate claims against different defendants can be aggregated to determine jurisdiction, as long as the claims arise from the same transaction

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    Flores v Mallere-Philipp 144 SCRA 377

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    Flores v Mallere-Philipp 144 SCRA 377

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    (1) Flores sued Binongcal and Calion separately in the RTC to collect debts for truck tires purchased on credit. Binongcal's debt was P11,643 while Calion's was P10,212. (2) Binongcal argued the RTC lacked jurisdiction over the case against him alone, as the amount was below the RTC's threshold of P20,000. However, the RTC ruled it had jurisdiction when considering the total debt (P11,643 + P10,212). (3) The Supreme Court affirmed, noting that under the new totality rule, separate claims against different defendants can be aggregated to determine jurisdiction, as long as the claims arise from the same transaction

    Copyright:

    © All Rights Reserved
    Download as DOC, PDF, TXT or read online from Scribd
    Download as doc, pdf, or txt
    516 views2 pages

    Flores V Mallere-Philipp 144 SCRA 377

    Uploaded by

    Vic Rabaya
    (1) Flores sued Binongcal and Calion separately in the RTC to collect debts for truck tires purchased on credit. Binongcal's debt was P11,643 while Calion's was P10,212. (2) Binongcal argued the RTC lacked jurisdiction over the case against him alone, as the amount was below the RTC's threshold of P20,000. However, the RTC ruled it had jurisdiction when considering the total debt (P11,643 + P10,212). (3) The Supreme Court affirmed, noting that under the new totality rule, separate claims against different defendants can be aggregated to determine jurisdiction, as long as the claims arise from the same transaction

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    of 2

    Flores v Mallere-Phillipps that, after a careful scrutiny of the complaint, it

    appears that there is a misjoinder of parties for


    G.R. No. L-66620 September 24, 1986 the reason that the claims against resps
    Binongcal and Calion are separate and distinct
    FACTS:
    and neither of which falls within its jurisdiction.
    Flores sued the respondents for the
    The lower court has jurisdiction over the
    collection of sum of money with the RTC:
    case following the "novel" totality rule
    (1) alleged in the complaint was against introduced in Section 33(l) of BP129 and Section
    Ignacio Binongcal for refusing to pay the 11 of the Interim Rules.
    amount of P11,643 representing cost of
    Section 33(l) of BP129:
    truck tires which he purchased on credit
    from Flores on various occasions from That where there are several claims or
    August to October, 1981; causes of action between the same or
    different parties, embodied in the same
    (2) was against resp Fernando Calion for
    complaint, the amount of the demand
    allegedly refusing to pay the amount of
    shall be the totality of the claims in all the
    P10,212 representing cost of truck tires
    causes of action, irrespective of whether
    which he purchased on credit from pet on
    the causes of action arose out of the same
    several occasions from March, 1981 to
    or different transactions. ...
    January, 1982.
    Section 11 of the Interim Rules:
    Binongcal filed a MTD on the ground of
    lack of jurisdiction since the amount of the Application of the totality rule. In actions
    demand against said resp was only P11,643.00, where the jurisdiction of the court is
    and under Section 19(8) of BP129 the RTC shall dependent on the amount involved, the
    exercise exclusive original jurisdiction if the test of jurisdiction shall be the aggregate
    amount of the demand is more than P20K. sum of all the money demands, exclusive
    only of interest and costs, irrespective of
    Although another person, Fernando
    WON the separate claims are owned by or
    Calion, was allegedly indebted to pet in the
    due to different parties. If any demand is
    amount of P10,212.00, his obligation was
    for damages in a civil action, the amount
    separate and distinct from that of the other resp.
    thereof must be specifically alleged.
    Calion joined in moving for the dismissal of the
    complaint. Former rule under Section 88 of the
    Judiciary Act of 1948 :
    RTC Decision: dismissed the complaint for lack
    of jurisdiction. Where there are several claims or causes
    of action between the same parties
    embodied in the same complaint, the
    ISSUE: amount of the demand shall be the totality
    of the demand in all the causes of action,
    WoN the RTC correctly ruled on the irrespective of whether the causes of
    application of the permissive joinder of parties. 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
    HELD: YES, RTC had correctly ruled on the
    to different parties, each separate claim
    application of the permissive joinder of
    shall furnish the jurisdictional test.
    parties.
    Under the present law, the two cases
    The lower court correctly held that
    would be under the jurisdiction of the RTC.
    the jurisdictional test is subject to the rules on
    Similarly, Brillo vs. Buklatan and Gacula vs.
    joinder of parties pursuant to Section 5 of Rule 2
    Martinez, if the (1) separate claims against
    and Section 6 of Rule 3 of the Rules of Court and
    the several defendants arose out of the same
    transaction or series of transactions and (2)
    there is a common question of law or fact,
    they would now be under the jurisdiction of the
    RTC.

    In cases of permissive joinder of


    parties, whether as plaintiffs or as defendants,
    under Section 6 of Rule 3, the total of all the
    claims shall now furnish the jurisdictional test.
    Needless to state also, if instead of joining or
    being joined in one complaint separate actions
    are filed by or against the parties, the amount
    demanded in each complaint shall furnish the
    jurisdictional test.

    DOCTRINE: The following are requisites for a


    Joinder of Parties, Sec. 6, Rule 3, Rules of Court:

    (1) A right to relief in respect or arising out of


    the same transaction or series of transactions;
    and

    (2) A common question of law or fact.

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