Case Digest (G.R. No. 208213)
Facts:
Ayala Land, Inc. v. The (Alleged) Heirs of the Late Lucas Lactao and Silvestra Aquino, G.R. No. 208213, August 08, 2018, First Division, Tijam, J., writing for the Court. The petition arises from the Court of Appeals' disposition in CA-G.R. SP No. 122999 and involves numerous earlier proceedings including CA-G.R. SP No. 99631 and petitions to this Court (e.g., G.R. No. 184376).Respondents (the alleged heirs) filed Complaint for quieting of title, annulment and cancellation of titles with reconveyance in the Regional Trial Court (RTC), docketed Civil Case No. Q‑05‑56296, alleging ancestral possession of Lot 42‑B‑1 (approx. 215,464 sq.m.) and forcible dispossession by petitioner Ayala Land, Inc. and co‑defendant Capitol Hills Golf and Country Club, Inc. Respondents initially paid P6,828.80 in docket fees and executed an Affidavit of Undertaking to allow a first lien on any monetary judgment for any deficiency in fees.
Petitioner and Capitol Hills moved to dismiss for lack of jurisdiction and insufficient filing fees, arguing that the correct filing fee (based on fair market/zonal valuation) was far higher (petitioner computed ≈ P62,903,240.00). The RTC denied the motion, granted a TRO, and the parties litigated the correctness of the fee assessment. Petitioner sought certiorari before the CA (docketed CA‑G.R. SP No. 99631), which in a May 2, 2008 decision denied certiorari but ordered the RTC clerk to reassess the correct docket fees under Section 7(a), Rule 141; both parties' motions for reconsideration were denied and related petitions to this Court (including G.R. No. 184376 and G.R. No. 184388) were likewise denied with finality on January 19, 2009 (entry of judgment June 16, 2009).
On remand, the RTC repeatedly instructed respondents to supply documents for reassessment and to pay the recomputed fees; respondents filed an Omnibus Motion (May 24, 2010) requesting (among other relief) a hearing to determine whether additional filing fees should be computed on pre‑taking or current market value and asking that any additional filing fees constitute a lien on the judgment because they claimed indigence. Petitioner moved to dismiss for respondents' failure to pay (Section 3, Rule 17). The RTC (Branch 96) in an August 18, 2011 Resolution denied the motion to dismiss, treated respondents as indigent for purposes of the fees, and set the case for pre‑trial; it later denied reconsideration but still directed reassessment by the clerk. Respondents then moved to be allowed to prosecute as pauper litigants; in an Order dated May 4, 2012 the RTC granted that motion.
Petitioner filed certiorari with the CA (docketed CA‑G.R. SP No. 122999) assailing the RTC's August 18 and November 21, 2011 resolutions as grave abuse of discretion. The CA, however, held on March 6, 2013 that the May 4, 2012 Order granting pauper‑litigant status rendered the certiorar...(Subscriber-Only)
Issues:
- Was the Court of Appeals correct to dismiss petitioner’s certiorari petition in CA‑G.R. SP No. 122999 as moot and academic due to the RTC’s May 4, 2012 Order declaring respondents pauper litigants?
- Should the Complaint in Civil Case No. Q‑05‑56296 have been dismissed with prejudice for respondents’ alleged failure to comply with final court directives to pay additional docket fees?
- Did the RTC properly grant respondents the privilege to litigate as indigent parties, and what is the proper forum and standard for resolving that factual question and the at...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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