Lawyerly

GR Nos. 178382-83

2015-09-23

JARDELEZA, J.

Jurisdiction is defined as the power and authority of the courts to hear, try and decide cases. Jurisdiction over the subject matter is conferred by the Constitution or by law and by the material allegations in the complaint, regardless of whether or not the plaintiff is entitled to recover all or some of the claims or reliefs sought therein.[42] It cannot be acquired through a waiver or enlarged by the omission of the parties or conferred by the acquiescence of the court.[43] That the employment contract of Basso was replete with references to US laws, and that it originated from and was returned to the US, do not automatically preclude our labor tribunals from exercising jurisdiction to hear and try this case.

GR No. 185666

2015-02-04

NIPPON EXPRESS CORP. v. CIR

PEREZ, J.

It must be emphasized that jurisdiction over the subject matter or nature of an action is fundamental for a court to act on a given controversy,[33] and is conferred only by law and not by the consent or waiver upon a court which, otherwise, would have no jurisdiction over the subject matter or nature of an action. Lack of jurisdiction of the court over an action or the subject matter of an action cannot be cured by the silence, acquiescence, or even by express consent of the parties.[34] If the court has no jurisdiction over the nature of an action, its only jurisdiction is to dismiss the case. The court could not decide the case on the merits.[35]

GR No. 185969

2014-11-19

AT&T COMMUNICATIONS SERVICES PHILIPPINES v. CIR

PEREZ, J.

At this juncture, it bears emphasis that jurisdiction over the subject matter or nature of an action is fundamental for a court to act on a given controversy,[18] and is conferred only by law and not by the consent or waiver upon a court which, otherwise, would have no jurisdiction over the subject matter or nature of an action. Lack of jurisdiction of the court over an action or the subject matter of an action cannot be cured by the silence, acquiescence, or even by express consent of the parties.[19] If the court has no jurisdiction over the nature of an action, its only jurisdiction is to dismiss the case. The court could not decide the case on the merits.[20] Needless to state, to obviate the possibility that its decision may be rendered void, the Court can, by its own initiative, raise the question of jurisdiction, although not raised by the parties.[21] As a corollary thereto, to inquire into the existence of jurisdiction over the subject matter is the primary concern of a court, for thereon would depend the validity of its entire proceedings.[22] Therefore, even if there was no jurisdictional issue raised by any party, the Court may look into it at anytime of the proceedings, even during this appeal.

GR No. 185432

2014-06-04

MIRAMAR FISH COMPANY v. CIR

PEREZ, J.

It must be emphasized that jurisdiction over the subject matter or nature of an action is fundamental for a court to act on a given controversy,[36] and is conferred only by law and not by the consent or waiver upon a court which, otherwise, would have no jurisdiction over the subject matter or nature of an action. Lack of jurisdiction of the court over an action or the subject matter of an action cannot be cured by the silence, acquiescence, or even by express consent of the parties.[37] If the court has no jurisdiction over the nature of an action, its only jurisdiction is to dismiss the case. The court could not decide the case on the merits.[38]

GR No. 169778

2014-03-12

CIR v. SILICON PHILIPPINES

PEREZ, J.

Parenthetically, it must be emphasized that jurisdiction over the subject matter or nature of an action is fundamental for a court to act on a given controversy,[34] and is conferred only by law and not by the consent or waiver upon a court which, otherwise, would have no jurisdiction over the subject matter or nature of an action. Lack of jurisdiction of the court over an action or the subject matter of an action cannot be cured by the silence, acquiescence, or even by express consent of the parties.[35] If the court has no jurisdiction over the nature of an action, its only jurisdiction is to dismiss the case. The court could not decide the case on the merits.[36]

AM No. RTJ-11-2259

2013-10-22

MA. REGINA S. PERALTA v. JUDGE GEORGE E. OMELIO

PER CURIAM

With the failure to serve actual notice on these occupants and possessors, Branch 14 had not acquired jurisdiction over Sp. Proc. No. 7527-2004, and therefore the March 4, 2008 Decision rendered by respondent is null and void. A decision of the court without jurisdiction is null and void; hence, it can never logically become final and executory. Such a judgment may be attacked directly or collaterally.[78]

GR No. 165423

2011-01-19

NILO PADRE v. FRUCTOSA BAILLO

DEL CASTILLO, J.

Although the Badillo family correctly filed a case for accion publiciana, they pleaded their case before the wrong court. In civil cases involving realty or interest therein not within Metro Manila, the MTC has exclusive original jurisdiction only if the assessed value of the subject property or interest therein does not exceed P20,000.00.[33] As the assessed value of the property subject matter of this case is P26,940.00, and since more than one year had expired after the dispossession, jurisdiction properly belongs to the RTC.[34] Hence, the MTC has no judicial authority at all to try the case in the first place. "A decision of the court without jurisdiction is null and void; hence, it could never logically become final and executory. Such a judgment may be attacked directly or collaterally."[35]

GR No. 172217

2009-09-18

SPS. LYDIA FLORES-CRUZ AND REYNALDO I. CRUZ v. SPS. LEONARDO AND ILUMINADA GOLI-CRUZ

CORONA, J.

It is axiomatic that the nature of the action - on which depends the question of whether a suit is within the jurisdiction of the court - is determined solely by the allegations in the complaint[13] and the law at the time the action was commenced.[14] Only facts alleged in the complaint can be the basis for determining the nature of the action and the court's competence to take cognizance of it. [15] One cannot advert to anything not set forth in the complaint, such as evidence adduced at the trial, to determine the nature of the action thereby initiated.[16]

GR No. 164789

2009-08-27

CHRISTIAN GENERAL ASSEMBLY v. SPS. AVELINO C. IGNACIO AND PRISCILLA T. IGNACIO

BRION, J.

The nature of an action and the jurisdiction of a tribunal are determined by the material allegations of the complaint and the law governing at the time the action was commenced. The jurisdiction of the tribunal over the subject matter or nature of an action is conferred only by law, not by the parties' consent or by their waiver in favor of a court that would otherwise have no jurisdiction over the subject matter or the nature of an action.[14] Thus, the determination of whether the CGA's cause of action falls under the jurisdiction of the HLURB necessitates a closer examination of the laws defining the HLURB's jurisdiction and authority.

GR No. 176709

2009-05-08

FORT BONIFACIO DEVELOPMENT CORPORATION v. EDWIN D. SORONGON

TINGA, J.

Jurisdiction is defined as the authority to try, hear and decide a case.[11] Moreover, that jurisdiction of the court over the subject matter is determined by the allegations of the complaint without regard to whether or not the plaintiff is entitled to recover upon all or some of the claims asserted therein is a well entrenched principle.[12] In this regard, the jurisdiction of the court does not depend upon the defenses pleaded in the answer or in the motion to dismiss, lest the question of jurisdiction would almost entirely depend upon the defendant.[13]

GR No. 145867

2009-04-07

ESTATE OF SOLEDAD MANANTAN v. ANICETO SOMERA

CHICO-NAZARIO, J.

Since the Complaint in Civil Case No. 10467 failed to satisfy on its face the jurisdictional requirements for an action for unlawful detainer, the Court of Appeals was correct in holding that the MTCC had no jurisdiction over the said Complaint and should have dismissed the same. There is no possible argument around the lack of jurisdiction of MTCC over Civil Case No. 10467. In Laresma v. Abellana,[28] the Court pronounced:It is axiomatic that the nature of an action and the jurisdiction of a tribunal are determined by the material allegations of the complaint and the law at the time the action was commenced. Jurisdiction of the tribunal over the subject matter or nature of an action is conferred only by law and not by the consent or waiver upon a court which, otherwise, would have no jurisdiction over the subject matter or nature of an action. Lack of jurisdiction of the court over an action or the subject matter of an action cannot be cured by the silence, acquiescence, or even by express consent of the parties. If the court has no jurisdiction over the nature of an action, it may dismiss the same ex mero motu or motu proprio. A decision of the court without jurisdiction is null and void; hence, it could never logically become final and executory. Such a judgment may be attacked directly or collaterally.

GR No. 180146

2008-12-18

PO2 RUEL C. MONTOYA v. POLICE DIRECTOR REYNALDO P. VARILLA

CHICO-NAZARIO, J.

A decision of the court (or, in this case, a quasi-judicial administrative body) without jurisdiction is null and void; hence, it can never logically become final and executory. Such a judgment may be attacked directly or collaterally.[23] Any judgment or decision rendered notwithstanding the violation of due process may be regarded as a lawless thing which can be treated as an outlaw and slain at sight, or ignored wherever it exhibits its head.[24]

GR No. 180394

2008-09-29

MARJORIE B. CADIMAS v. MARITES CARRION

TINGA, J.

The nature of an action and the jurisdiction of a tribunal are determined by the material allegations of the complaint and the law at the time the action was commenced. Jurisdiction of the tribunal over the subject matter or nature of an action is conferred only by law and not by the consent or waiver upon a court which, otherwise, would have no jurisdiction over the subject matter or nature of an action.[15]

GR No. 178266

2008-07-21

PEOPLE v. SAMUEL

NACHURA, J.

First. It is a well-entrenched doctrine that the jurisdiction of a tribunal over the subject matter of an action is conferred by law. It is determined by the material allegations of the complaint or information and the law at the time the action was commenced. Lack of jurisdiction of the court over an action or the subject matter of an action, cannot be cured by the silence, acquiescence, or even by express consent of the parties. Thus, the jurisdiction of the court over the nature of the action and the subject matter thereof cannot be made to depend upon the defenses set up in the court or upon a motion to dismiss; otherwise, the question of jurisdiction would depend almost entirely on the defendant. Once jurisdiction is vested, the same is retained up to the end of the litigation.[16]

GR No. 162894

2008-02-26

RAYTHEON INTERNATIONAL v. STOCKTON W. ROUZIE

TINGA, J,

Jurisdiction over the nature and subject matter of an action is conferred by the Constitution and the law[30] and by the material allegations in the complaint, irrespective of whether or not the plaintiff is entitled to recover all or some of the claims or reliefs sought therein.[31] Civil Case No. 1192-BG is an action for damages arising from an alleged breach of contract. Undoubtedly, the nature of the action and the amount of damages prayed are within the jurisdiction of the RTC.

GR No. 155179

2007-08-24

VICTORINO QUINAGORAN v. CA

AUSTRIA-MARTINEZ, J.

In no uncertain terms, the Court has already held that a complaint must allege the assessed value of the real property subject of the complaint or the interest thereon to determine which court has jurisdiction over the action.[30] This is because the nature of the action and which court has original and exclusive jurisdiction over the same is determined by the material allegations of the complaint, the type of relief prayed for by the plaintiff and the law in effect when the action is filed, irrespective of whether the plaintiffs are entitled to some or all of the claims asserted therein.[31]

GR No. 143111

2007-06-07

LORETO REYES v. SPS. HONORIO AND JOSEFINA B. JOSON

SANDOVAL-GUTIERREZ, J.

The essential requisites to establish a tenancy relationship are: 1) that the parties are the landowner and the tenant or agricultural lessee; 2) that the subject matter of the relationship is agricultural land; 3) that there is consent between the parties to the relationship; 4) that the purpose of the relationship is to bring about agricultural production; 5) that there is personal cultivation on the part of the tenant or agricultural lessee; and 6) that the harvest is shared between the landowner and the tenant or agricultural lessee.[4]

GR No. 144244

2005-11-11

ESTER DELOSO v. SPS. ALFONSO MARAPAO AND HERMINIA P. MARAPAO

TINGA, J.

In order to establish a tenancy relationship, the following essential requisites must concur: (1) that the parties are the landowner and the tenant or agricultural lessee; (2) that the subject matter of the relationship is an agricultural land; (3) that there is consent between the parties to the relationship; (4) that the purpose of the relationship is to bring about agricultural production; (5) that there is personal cultivation on the part of the tenant or agricultural lessee; and (6) that the harvest is shared between the landowner and the tenant or agricultural lessee.[15]

GR NO. 143951

2005-10-25

NORMA MANGALIAG v. EDELWINA CATUBIG-PASTORAL

AUSTRIA-MARTINEZ, J.

The well-entrenched principle is that the jurisdiction of the court over the subject matter of the action is determined by the material allegations of the complaint and the law, irrespective of whether or not the plaintiff is entitled to recover all or some of the claims or reliefs sought therein.[29] In the present case, the allegations in the complaint plainly show that private respondent seeks to recover not only his medical expenses, lost income but also damages for physical suffering and mental anguish due to permanent facial deformity from injuries sustained in the vehicular accident. Viewed as an action for quasi-delict, the present case falls squarely within the purview of Article 2219 (2),[30] which provides for the payment of moral damages in cases of quasi-delict causing physical injuries.

	GR Nos. 178382-83 2015-09-23	CONTINENTAL MICRONESIA v. JOSEPH BASSO JARDELEZA, J.
Jurisdiction is defined as the power and authority of the courts to hear, try and decide cases. Jurisdiction over the subject matter is conferred by the Constitution or by law and by the material allegations in the complaint, regardless of whether or not the plaintiff is entitled to recover all or some of the claims or reliefs sought therein.[42] It cannot be acquired through a waiver or enlarged by the omission of the parties or conferred by the acquiescence of the court.[43] That the employment contract of Basso was replete with references to US laws, and that it originated from and was returned to the US, do not automatically preclude our labor tribunals from exercising jurisdiction to hear and try this case.
	GR No. 185666 2015-02-04	NIPPON EXPRESS CORP. v. CIR PEREZ, J.
It must be emphasized that jurisdiction over the subject matter or nature of an action is fundamental for a court to act on a given controversy,[33] and is conferred only by law and not by the consent or waiver upon a court which, otherwise, would have no jurisdiction over the subject matter or nature of an action. Lack of jurisdiction of the court over an action or the subject matter of an action cannot be cured by the silence, acquiescence, or even by express consent of the parties.[34] If the court has no jurisdiction over the nature of an action, its only jurisdiction is to dismiss the case. The court could not decide the case on the merits.[35]
	GR No. 185969 2014-11-19	AT&T COMMUNICATIONS SERVICES PHILIPPINES v. CIR PEREZ, J.
At this juncture, it bears emphasis that jurisdiction over the subject matter or nature of an action is fundamental for a court to act on a given controversy,[18] and is conferred only by law and not by the consent or waiver upon a court which, otherwise, would have no jurisdiction over the subject matter or nature of an action. Lack of jurisdiction of the court over an action or the subject matter of an action cannot be cured by the silence, acquiescence, or even by express consent of the parties.[19] If the court has no jurisdiction over the nature of an action, its only jurisdiction is to dismiss the case. The court could not decide the case on the merits.[20] Needless to state, to obviate the possibility that its decision may be rendered void, the Court can, by its own initiative, raise the question of jurisdiction, although not raised by the parties.[21] As a corollary thereto, to inquire into the existence of jurisdiction over the subject matter is the primary concern of a court, for thereon would depend the validity of its entire proceedings.[22] Therefore, even if there was no jurisdictional issue raised by any party, the Court may look into it at anytime of the proceedings, even during this appeal.
	GR No. 185432 2014-06-04	MIRAMAR FISH COMPANY v. CIR PEREZ, J.
It must be emphasized that jurisdiction over the subject matter or nature of an action is fundamental for a court to act on a given controversy,[36] and is conferred only by law and not by the consent or waiver upon a court which, otherwise, would have no jurisdiction over the subject matter or nature of an action. Lack of jurisdiction of the court over an action or the subject matter of an action cannot be cured by the silence, acquiescence, or even by express consent of the parties.[37] If the court has no jurisdiction over the nature of an action, its only jurisdiction is to dismiss the case. The court could not decide the case on the merits.[38]
	GR No. 169778 2014-03-12	CIR v. SILICON PHILIPPINES PEREZ, J.
Parenthetically, it must be emphasized that jurisdiction over the subject matter or nature of an action is fundamental for a court to act on a given controversy,[34] and is conferred only by law and not by the consent or waiver upon a court which, otherwise, would have no jurisdiction over the subject matter or nature of an action. Lack of jurisdiction of the court over an action or the subject matter of an action cannot be cured by the silence, acquiescence, or even by express consent of the parties.[35] If the court has no jurisdiction over the nature of an action, its only jurisdiction is to dismiss the case. The court could not decide the case on the merits.[36]
	AM No. RTJ-11-2259 2013-10-22	MA. REGINA S. PERALTA v. JUDGE GEORGE E. OMELIO PER CURIAM
With the failure to serve actual notice on these occupants and possessors, Branch 14 had not acquired jurisdiction over Sp. Proc. No. 7527-2004, and therefore the March 4, 2008 Decision rendered by respondent is null and void. A decision of the court without jurisdiction is null and void; hence, it can never logically become final and executory. Such a judgment may be attacked directly or collaterally.[78]
	GR No. 165423 2011-01-19	NILO PADRE v. FRUCTOSA BAILLO DEL CASTILLO, J.
Although the Badillo family correctly filed a case for accion publiciana, they pleaded their case before the wrong court. In civil cases involving realty or interest therein not within Metro Manila, the MTC has exclusive original jurisdiction only if the assessed value of the subject property or interest therein does not exceed P20,000.00.[33] As the assessed value of the property subject matter of this case is P26,940.00, and since more than one year had expired after the dispossession, jurisdiction properly belongs to the RTC.[34] Hence, the MTC has no judicial authority at all to try the case in the first place. "A decision of the court without jurisdiction is null and void; hence, it could never logically become final and executory. Such a judgment may be attacked directly or collaterally."[35]
	GR No. 172217 2009-09-18	SPS. LYDIA FLORES-CRUZ AND REYNALDO I. CRUZ v. SPS. LEONARDO AND ILUMINADA GOLI-CRUZ CORONA, J.
It is axiomatic that the nature of the action - on which depends the question of whether a suit is within the jurisdiction of the court - is determined solely by the allegations in the complaint[13] and the law at the time the action was commenced.[14] Only facts alleged in the complaint can be the basis for determining the nature of the action and the court's competence to take cognizance of it. [15] One cannot advert to anything not set forth in the complaint, such as evidence adduced at the trial, to determine the nature of the action thereby initiated.[16]
	GR No. 164789 2009-08-27	CHRISTIAN GENERAL ASSEMBLY v. SPS. AVELINO C. IGNACIO AND PRISCILLA T. IGNACIO BRION, J.
The nature of an action and the jurisdiction of a tribunal are determined by the material allegations of the complaint and the law governing at the time the action was commenced. The jurisdiction of the tribunal over the subject matter or nature of an action is conferred only by law, not by the parties' consent or by their waiver in favor of a court that would otherwise have no jurisdiction over the subject matter or the nature of an action.[14] Thus, the determination of whether the CGA's cause of action falls under the jurisdiction of the HLURB necessitates a closer examination of the laws defining the HLURB's jurisdiction and authority.
	GR No. 176709 2009-05-08	FORT BONIFACIO DEVELOPMENT CORPORATION v. EDWIN D. SORONGON TINGA, J.
Jurisdiction is defined as the authority to try, hear and decide a case.[11] Moreover, that jurisdiction of the court over the subject matter is determined by the allegations of the complaint without regard to whether or not the plaintiff is entitled to recover upon all or some of the claims asserted therein is a well entrenched principle.[12] In this regard, the jurisdiction of the court does not depend upon the defenses pleaded in the answer or in the motion to dismiss, lest the question of jurisdiction would almost entirely depend upon the defendant.[13]
	GR No. 145867 2009-04-07	ESTATE OF SOLEDAD MANANTAN v. ANICETO SOMERA CHICO-NAZARIO, J.
Since the Complaint in Civil Case No. 10467 failed to satisfy on its face the jurisdictional requirements for an action for unlawful detainer, the Court of Appeals was correct in holding that the MTCC had no jurisdiction over the said Complaint and should have dismissed the same. There is no possible argument around the lack of jurisdiction of MTCC over Civil Case No. 10467. In Laresma v. Abellana,[28] the Court pronounced:It is axiomatic that the nature of an action and the jurisdiction of a tribunal are determined by the material allegations of the complaint and the law at the time the action was commenced. Jurisdiction of the tribunal over the subject matter or nature of an action is conferred only by law and not by the consent or waiver upon a court which, otherwise, would have no jurisdiction over the subject matter or nature of an action. Lack of jurisdiction of the court over an action or the subject matter of an action cannot be cured by the silence, acquiescence, or even by express consent of the parties. If the court has no jurisdiction over the nature of an action, it may dismiss the same ex mero motu or motu proprio. A decision of the court without jurisdiction is null and void; hence, it could never logically become final and executory. Such a judgment may be attacked directly or collaterally.
	GR No. 180146 2008-12-18	PO2 RUEL C. MONTOYA v. POLICE DIRECTOR REYNALDO P. VARILLA CHICO-NAZARIO, J.
A decision of the court (or, in this case, a quasi-judicial administrative body) without jurisdiction is null and void; hence, it can never logically become final and executory. Such a judgment may be attacked directly or collaterally.[23] Any judgment or decision rendered notwithstanding the violation of due process may be regarded as a lawless thing which can be treated as an outlaw and slain at sight, or ignored wherever it exhibits its head.[24]
	GR No. 180394 2008-09-29	MARJORIE B. CADIMAS v. MARITES CARRION TINGA, J.
The nature of an action and the jurisdiction of a tribunal are determined by the material allegations of the complaint and the law at the time the action was commenced. Jurisdiction of the tribunal over the subject matter or nature of an action is conferred only by law and not by the consent or waiver upon a court which, otherwise, would have no jurisdiction over the subject matter or nature of an action.[15]
	GR No. 178266 2008-07-21	PEOPLE v. SAMUEL NACHURA, J.
First. It is a well-entrenched doctrine that the jurisdiction of a tribunal over the subject matter of an action is conferred by law. It is determined by the material allegations of the complaint or information and the law at the time the action was commenced. Lack of jurisdiction of the court over an action or the subject matter of an action, cannot be cured by the silence, acquiescence, or even by express consent of the parties. Thus, the jurisdiction of the court over the nature of the action and the subject matter thereof cannot be made to depend upon the defenses set up in the court or upon a motion to dismiss; otherwise, the question of jurisdiction would depend almost entirely on the defendant. Once jurisdiction is vested, the same is retained up to the end of the litigation.[16]
	GR No. 162894 2008-02-26	RAYTHEON INTERNATIONAL v. STOCKTON W. ROUZIE TINGA, J,
Jurisdiction over the nature and subject matter of an action is conferred by the Constitution and the law[30] and by the material allegations in the complaint, irrespective of whether or not the plaintiff is entitled to recover all or some of the claims or reliefs sought therein.[31] Civil Case No. 1192-BG is an action for damages arising from an alleged breach of contract. Undoubtedly, the nature of the action and the amount of damages prayed are within the jurisdiction of the RTC.
	GR No. 155179 2007-08-24	VICTORINO QUINAGORAN v. CA AUSTRIA-MARTINEZ, J.
In no uncertain terms, the Court has already held that a complaint must allege the assessed value of the real property subject of the complaint or the interest thereon to determine which court has jurisdiction over the action.[30] This is because the nature of the action and which court has original and exclusive jurisdiction over the same is determined by the material allegations of the complaint, the type of relief prayed for by the plaintiff and the law in effect when the action is filed, irrespective of whether the plaintiffs are entitled to some or all of the claims asserted therein.[31]
	GR No. 143111 2007-06-07	LORETO REYES v. SPS. HONORIO AND JOSEFINA B. JOSON SANDOVAL-GUTIERREZ, J.
The essential requisites to establish a tenancy relationship are: 1) that the parties are the landowner and the tenant or agricultural lessee; 2) that the subject matter of the relationship is agricultural land; 3) that there is consent between the parties to the relationship; 4) that the purpose of the relationship is to bring about agricultural production; 5) that there is personal cultivation on the part of the tenant or agricultural lessee; and 6) that the harvest is shared between the landowner and the tenant or agricultural lessee.[4]
	GR No. 144244 2005-11-11	ESTER DELOSO v. SPS. ALFONSO MARAPAO AND HERMINIA P. MARAPAO TINGA, J.
In order to establish a tenancy relationship, the following essential requisites must concur: (1) that the parties are the landowner and the tenant or agricultural lessee; (2) that the subject matter of the relationship is an agricultural land; (3) that there is consent between the parties to the relationship; (4) that the purpose of the relationship is to bring about agricultural production; (5) that there is personal cultivation on the part of the tenant or agricultural lessee; and (6) that the harvest is shared between the landowner and the tenant or agricultural lessee.[15]
	GR NO. 143951 2005-10-25	NORMA MANGALIAG v. EDELWINA CATUBIG-PASTORAL AUSTRIA-MARTINEZ, J.
The well-entrenched principle is that the jurisdiction of the court over the subject matter of the action is determined by the material allegations of the complaint and the law, irrespective of whether or not the plaintiff is entitled to recover all or some of the claims or reliefs sought therein.[29] In the present case, the allegations in the complaint plainly show that private respondent seeks to recover not only his medical expenses, lost income but also damages for physical suffering and mental anguish due to permanent facial deformity from injuries sustained in the vehicular accident. Viewed as an action for quasi-delict, the present case falls squarely within the purview of Article 2219 (2),[30] which provides for the payment of moral damages in cases of quasi-delict causing physical injuries.

JUSTINO LARESMA v. ANTONIO P. ABELLANA