G.R. No. 233181 - Apacible vs. People

In 1999, petitioner Rosario M. Apacible (Apacible) entered into a dealership agreement with private respondent San Miguel Corporation (SMC), authorizing her to deliver San Miguel products in Nasugbu, Batangas and other municipalities.
SMC later terminated the contract due to Apacible’s delinquency in paying her obligations.

Apacible executed an Undertaking on December 16, 1999, acknowledging an indebtedness to SMC amounting to P3,957,173.60 representing unpaid returned checks.
To pay the outstanding obligation, Apacible issued eight post-dated checks with four specifically involved in the case, each amounting to P500,000.00, dated from December 31, 1999 to March 31, 2000.

The four checks were dishonored upon presentment due to insufficiency of funds and account closure.
SMC sent Apacible several demand letters in January, May, and November 2000 notifying the dishonor and demanding payment, but Apacible failed to satisfy the obligation.

SMC filed a complaint-affidavit leading to four separate Informations for violation of Batas Pambansa Blg. 22 (B.P. 22) filed in 2003 before the Municipal Trial Court in Cities (MTCC), City of Calamba.
Apacible filed a Demurrer to Evidence in 2011, which the MTCC granted in 2012, acquitting her in the criminal aspect due to insufficiency of evidence, specifically failure to prove receipt of notice of dishonor.
The MTCC, however, proceeded with the civil aspect of the case, setting the presentation of defense evidence in May 2012.

Apacible filed a Partial Motion for Reconsideration questioning MTCC’s jurisdiction over the civil aspect due to claims exceeding jurisdictional amounts, which was denied.
Apacible filed multiple motions including Omnibus Motions for Clarification, Motions for Reconsideration, and motions to suspend proceedings, all denied by the MTCC, which admonished her for dilatory tactics.
The MTCC enumerated at least twelve postponement motions and other pleadings filed by Apacible from 2003 to 2013, contributing to significant delays in the case.

On April 8, 2014, the MTCC rendered judgment holding Apacible civilly liable to SMC for P2,000,000.00 (P500,000.00 for each of the four checks plus 12% interest from July 31, 2003).
Apacible moved for reconsideration on jurisdictional grounds, which was denied.
She filed an appeal to the Regional Trial Court (RTC) of Calamba City.

The RTC affirmed the MTCC ruling, ruling that SMC could not be held responsible for nonpayment of docket fees and that the Clerk of Court had sent notice for payment to SMC, which did not return the notice.
The payment of docket fees was recognized as a first lien on the judgment.
RTC also upheld Apacible’s civil liability, denying her motions for reconsideration.

On November 23, 2016, the CA affirmed with modification the RTC decision, ordering Apacible to pay SMC the same P500,000.00 amounts for each check, but reduced interest to 6% per annum from July 31, 2003 until fully satisfied.
The CA emphasized that Apacible failed to raise the issue concerning docket fees at the MTCC level, and the RTC correctly created a lien for docket fees on the monetary award.
The CA differentiated that unlike purely civil cases where docket fees must be paid upfront to vest jurisdiction, in B.P. 22 cases the civil action is deemed initiated with the criminal complaint, allowing docket fees to become a lien on judgment.

Apacible filed a petition for review on certiorari under Rule 45 to question MTCC’s jurisdiction over the civil aspect of the case for failure of SMC to pay docket fees at the time of filing.
She argued that all lower court proceedings and judgments are void for lack of jurisdiction.

Did the MTCC acquire jurisdiction over the civil aspect of the B.P. 22 cases despite SMC’s failure to pay docket fees upon filing?
Can Apacible raise the question of jurisdiction for failure to pay docket fees after actively participating in the proceedings and after more than 11 years?
Is it proper to allow docket fees to be charged as a lien over the monetary award in B.P. 22 cases?
Should the interest be applied at 12% or 6% per annum?