G.R. No. 96724 - People vs. Claravall

Benneth Thelmo filed a sworn complaint with the Office of the Public Prosecutor of Rizal, accusing Honesto General and another person of libel.
The complaint alleged that, because of the libelous act, Thelmo suffered actual, moral, and exemplary damages totaling P100 million.

The information for libel, subsequently filed with the Regional Trial Court (RTC) at Pasig, did not contain any allegation regarding the damages claim.
During trial, the defense objected on the ground that the docket fees corresponding to Thelmo’s claim for damages were not paid when the complaint was filed before the fiscal.
The RTC overruled the objection and confirmed the payment issue by issuing an Order on March 28, 1990.
Further, the defendants’ subsequent motions for reconsideration and for suspension of proceedings were denied by another Order dated May 17, 1990.

Petitioner Honesto General, together with his co-accused, filed a petition for a writ of certiorari with this Court.
Their contention was that the trial court Orders had been rendered with grave abuse of discretion, particularly concerning the filing fees issue.

The petition involved an inquiry into the application of existing doctrines as elucidated in three earlier decisions:

The Manchester doctrine required that a complaint must specify both the claim for damages in the body and the prayer, and that the corresponding filing fees be paid at the time of filing.
The decisions in Sun Insurance and Tacay modified the strictness of the Manchester doctrine by providing that:

Claims for which amounts were not specified might be refused acceptance or expunged.
A defect in the complaint could be remedied by granting a motion to allow amendment and payment of the requisite filing fees, as long as the period of limitation had not lapsed.

At the time of the Manchester decision, Section 1, Rule 111 of the 1985 Rules of Criminal Procedure mandated that the filing fees for the civil action impliedly instituted with the criminal action be paid upon initial filing, irrespective of whether the damages amount was included in the information.
The Revised (1988) Rules on Criminal Procedure, effective October 1, 1988, amended Section 1, Rule 111:

When the complaint or information includes the alleged amount of damages (other than actual damages), the offended party must pay the corresponding filing fees upon filing.
In cases where such amounts are not alleged, the filing fees are not required at filing but will constitute a first lien on any judgment (except in an award for actual damages).

The amendments were intended to clarify the payment obligations and to discourage the practice of omitting damage amounts solely to evade the correct filing fees.

Whether the omission of an alleged specific amount of damages in the complaint or information constitutes a valid basis for not requiring the immediate payment of docket fees for the implied civil action under Section 1, Rule 111.

Examination of whether the rule as set forth in the Manchester doctrine is applicable in cases where the damages amount is not specified.
Consideration of the amendments made by the 1988 Rules on Criminal Procedure in modifying the strict application of the Manchester rule.

Whether the Orders of the RTC dated March 28, 1990 and May 17, 1990, regarding the non-payment of filing fees and the denial of subsequent motions, were rendered with grave abuse of discretion.

Analysis of if the trial court correctly applied the rules on filing fees for implied civil actions.
Determination of the propriety of penalizing the plaintiff for failing to specify a damages amount in the complaint.