Case Digest (G.R. No. 138894)
Facts:
The Heirs of the Late President Ferdinand E. Marcos, G.R. No. 138894, July 20, 2006, Supreme Court Second Division, Puno, J., writing for the Court. This petition for review on certiorari under Rule 45 seeks to set aside the Sandiganbayan's February 15, 1999 resolution dismissing Civil Case No. 0183 for alleged failure to pay the proper docket fees.On February 28, 1986, Executive Order No. 1 created the Presidential Commission on Good Government (PCGG) to recover ill-gotten wealth of former President Marcos and his associates. Pursuant to sequestrations and related actions, the PCGG filed civil suits in the name of the Republic, and in 1990 Roberto S. Benedicto settled several such actions by a compromise agreement surrendering 51% of his equity in Eastern Telecommunications Philippines, Inc. (ETPI) — 2,652,000 shares (par value P100 per share) — to the PCGG.
On April 17, 1998, petitioners (the Heirs of Ferdinand E. Marcos) sued the PCGG in the Sandiganbayan for declaration of ownership, accounting, and damages, claiming title to the surrendered ETPI shares and praying for P400,000 moral damages, P400,000 exemplary damages, P200,000 attorney’s fees, and costs. Petitioners paid a filing fee of P4,850. The PCGG answered on June 29, 1998; pretrial was set for October 9, 1998.
At pretrial the Sandiganbayan observed that the filing fee paid was insufficient under applicable fee rules and, invoking Section 7, Rule 141 of the Revised Rules of Court (as amended), Section 4, R.A. No. 7975, and Manchester Development Corporation v. Court of Appeals, required payment of the correct docket fee before the court could exercise jurisdiction. On October 14, 1998, the Sandiganbayan (Fourth Division) issued an order to show cause why the complaint should not be dismissed for lack of jurisdiction for nonpayment of the prescribed docket fee — computed to require an additional P1,326,955 given the value claimed.
Petitioners responded (Nov. 17, 1998) contending that application of Section 7, Rule 141 to the Sandiganbayan would unconstitutionally diminish rights under Section 11, P.D. No. 1606 (providing proceedings in the Sandiganbayan “free of charge”) and that subsequent statutes (R.A. Nos. 7975 and 8249) did not expressly repeal Section 11; they also argued that, because the Sandiganbayan is “of the same level” as the Court of Appeals, Sections 4 and 5, Rule 141 (fees for Court of Appeals/Supreme Court) should apply.
On February 15, 1999, the Sandiganbayan dismissed Civil Case No. 0183 for lack of jurisdiction due to nonpayment of proper filing fees. Petitioners’ motion for reconsideration was denied on May 24, 1999. They then filed this Rule 45 petition.
The Supreme Court, relying on earlier precedents including Yuchengco v. Republic of the Philippines (G.R. No. 131127, June 8, 2000) and Sun Insurance Office Ltd. v. Hon. Maximiano Asuncion (G.R. Nos. 79937...(Subscriber-Only)
Issues:
- Did the Sandiganbayan correctly dismiss the complaint for lack of jurisdiction because petitioners failed to pay the prescribed docket fees?
- Was Section 11, P.D. No. 1606 (proceedings in the Sandiganbayan free of charge) expressly or impliedly preserved despite the amendments effected by R.A. No. 7975 and R.A. No. 8249, or should Rule 141 (Sections 4, 5 or 7) govern docket fees before the Sandiganbayan?
- Assuming the jurisdictional defect could be cured, is petitioners’ action fo...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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