Facts:

The case of Acar v. Rosal involves a group of ten individuals, namely Felipe Acar and nine others, hereinafter referred to as the petitioners, who filed a complaint on February 21, 1963, in the Court of First Instance of Negros Oriental against various companies and individuals, including Compania General de Tabacos de Filipinas and Central Azucarera de Bais. The petitioners, acting on behalf of approximately 9,000 other farm laborers employed intermittently in sugar cane plantations in the Bais milling district, sought to recover an aggregate sum of ₱4,031,836.74. This claim was based on provisions from the Republic Act 809—the Sugar Act of 1952—which discusses the distribution of the unrefined sugar produced and its by-products between laborers and planters in sugar milling districts.

Due to their financial constraints, the petitioners requested permission from the court to litigate as pauper litigants, invoking Section 22, Rule 3 of the Rules of Court, which allows individual

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Facts:

Overview of the Case

• The case involves ten named petitioners filing a suit on their own behalf and that of approximately 9,000 other farm laborers employed in sugar cane plantations in the Bais milling district, Negros Oriental.
• The petitioners sought to recover their alleged participations or shares from the sugar, molasses, bagasse, and by-products as provided under Republic Act 809 (The Sugar Act of 1952), specifically invoking Sections 1 and 9 of the Act.

Relevant Statutory and Constitutional Provisions

• Republic Act 809
• Section 1 details the division of unrefined sugar and by-products between planters and milling centrals, using a graduated scale based on mill production.
• Section 9 provides that any increased participation (beyond the planters’ present share) must be divided between the laborers (60%) and the planters (40%), with the labor share supervised by the Department of Labor.
• Rules of Court
• Section 22 of Rule 3 allows a litigant to prosecute an action as a pauper upon proper demonstration of inability to afford court costs, thus dispensing with legal fees and bond requirements.
• The Philippine Constitution
• Section 21, Subsection (1) of Article III guarantees that “free access to the courts shall not be denied to any person by reason of poverty,” which is central to this case.

Factual Background Regarding the Pauper Litigant Issue

• The petitioners, being seasonal farm laborers with no property and dependent solely on daily wages, claimed indigence and a lack of financial means to pay the docket fee of P14,500.00.
• To support this claim, they submitted certificates from municipal treasurers stating that none of them had any real property registered in their names.
• A prior motion to litigate in forma pauperis was filed and was subsequently denied by the Court of First Instance on May 27, 1963, on the ground that the petitioners enjoyed regular employment and had sources of income.
• The petitioners sought reconsideration of the denial, but the order was affirmed on June 11, 1963.

Transition to the Present Action

• On August 1, 1963, the petitioners filed a special civil action for certiorari and mandamus challenging the denial of their application to litigate as paupers.
• They argued that the denial of their motion infringed upon their constitutional right to free access to the courts.
• On August 16, 1963, the higher court allowed the petitioners to litigate as paupers and ordered the respondent to answer.

Procedural History

• The respondent, the Hon. Inocencio Rosal in his capacity as Executive Judge of the Court of First Instance of Negros Oriental, filed his answer on November 2, 1963.
• After proceedings that included a hearing on February 10, 1964, the case was submitted for decision.
• The central factual issue revolved around whether the petitioners’ constitutional right to free access to the courts, regardless of poverty, had been violated by the earlier orders.

Issue:

Violation of Constitutional Right

• Whether the refusal to allow the petitioners to litigate as paupers denied them their constitutional right of “free access to the courts” as guaranteed under Section 21, Subsection (1) of Article III of the Philippine Constitution.

Applicability of the Definition of “Pauper”

• Whether the court’s reliance on the narrow definition of “pauper” (as someone so poor that he must be supported at public expense, per Black’s Law Dictionary) is appropriate in the context of suits in forma pauperis.
• Whether the broader notion of indigence—encompassing those who, despite having regular employment, do not have sufficient resources to fund the cost of litigation—should instead be applied.

Impact on Class Suit Litigation

• How the costs associated with filing, including the docket fee of P14,500.00, affect a class suit where the burden falls on the ten named petitioners representing approximately 9,000 laborers.
• Whether imposing such fees on the petitioners would effectively bar access to justice for those whose claims arise from common interest litigation.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)