Case Digest (G.R. No. 18513)
Facts:
In Felipe Acar, et al. v. Hon. Inocencio Rosal (125 Phil. 1009, decided March 18, 1967 under the 1935 Philippine Constitution), ten farm laborers of the Bais milling district in Negros Oriental filed a class suit on February 21, 1963 in the Court of First Instance against Compania General de Tabacos de Filipinas and other sugar centrals and individuals to recover an aggregate P4,031,836.74 representing their shares in sugar, molasses, bagasse, and by-products under Republic Act No. 809 (The Sugar Act of 1952), particularly Sections 1 and 9. Invoking Section 22, Rule 3 of the Rules of Court and Subsection 21, Section 1, Article III of the Constitution (“Free access to the courts shall not be denied to any person by reason of poverty”), they petitioned to litigate as pauper litigants, claiming inability to pay the P14,500 docket fee. The trial court denied their motion on May 27, 1963 and again on June 11, 1963, reasoning that petitioners had regular employment and were therefore ...Case Digest (G.R. No. 18513)
Facts:
- Constitutional and Statutory Framework
- Article III, Section 1(21) of the 1935 Constitution: “Free access to the courts shall not be denied to any person by reason of poverty.”
- Republic Act No. 809 (Sugar Act of 1952):
- Section 1 – Division of unrefined sugar and by-products between planters and centrals (percentages based on actual production).
- Section 9 – Distribution of any increase in planter’s participation: 60% to laborers and 40% to planters; benefits not to be diminished by piece-rate or other contracts.
- Underlying Class Suit
- On February 21, 1963, ten farm laborers filed a class suit in the Court of First Instance of Negros Oriental on behalf of themselves and some 9,000 fellow laborers against several sugar centrals and individuals.
- They sought to recover P4,031,836.74 representing their shares under Sections 1 and 9 of R.A. 809.
- Motion to Litigate as Pauper
- Plaintiffs moved under Section 22, Rule 3 of the Rules of Court, invoking the Constitutional free-access clause and alleging inability to pay the P14,500 docket fee. They submitted municipal treasurer certificates showing no real property.
- On May 27, 1963, and upon reconsideration on June 11, 1963, the CFI denied the motion, holding that plaintiffs had regular employment and thus were not paupers.
- Special Civil Action before the Supreme Court
- On August 1, 1963, petitioners filed a special civil action for certiorari and mandamus in the Supreme Court, challenging the CFI orders as depriving them of free access to the courts.
- The Supreme Court allowed them to litigate as paupers on August 16, 1963; respondent answered November 2, 1963; the case was submitted for decision on February 10, 1964.
Issues:
- Whether the denial by the CFI of petitioners’ motion to litigate as paupers deprived them of their constitutional right to free access to the courts by reason of poverty.
- Whether the term “pauper” for in forma pauperis purposes should be narrowly construed as a public charge or broadly construed to include indigent persons without means to pay legal fees.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)