Case Digest (G.R. No. 75919) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In an action filed before the Regional Trial Court, Manchester Development Corporation, et al. (petitioners), sought a writ of preliminary prohibitory injunction, attachment of properties, annulment of forfeiture, specific performance of a sale contract and damages (actual, compensatory and exemplary, plus attorney’s fees) against Cityland Development Corporation, Stephen Roxas, Andrew Luison, Grace Luison and Jose de Maisip (respondents). Although the body of the original complaint alleged over ₱78,750,000.00 in damages, petitioners paid only ₱410.00 as docket fee, treating the action as unliquidated. Upon learning of similar underpayments, this Court on October 15, 1985 ordered a re-assessment of docket fees. On November 12, 1985, the trial court directed petitioners to state the amount of damages in an amended complaint, which then alleged ₱10,000,000.00 in damages in its body but still omitted the figure in its prayer. Meanwhile, the Court of Appeals, Second Division, in a J Case Digest (G.R. No. 75919) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Original Complaint
- Petitioners filed an action for torts and damages, specific performance, and injunctive relief. The body of the complaint alleged damages totaling over ₱78,750,000, but the prayer did not specify any amount.
- Upon filing, petitioners paid a docket fee of ₱410.00, treating the case as one for specific performance “not capable of pecuniary estimation.”
- Subsequent Proceedings
- The Supreme Court, upon discovering the under-assessment of filing fees in this and similar cases, ordered an investigation and re-assessment. Petitioners, with leave of court, filed an amended complaint on September 12, 1985, adding Philips Wire and Cable Corporation as co-plaintiff and deleting all mention of damages.
- On November 12, 1985, the trial court directed petitioners to state the amount of damages in the amended complaint. They specified ₱10,000,000 in the body but still omitted any amount in the prayer. The amended complaint was then admitted.
- Comparison with Magaspi v. Ramolete
- In Magaspi, the action was for recovery of land and specified damages; initial fees (₱60.00 docket, ₱10.00 sheriff) were underpaid due to an “honest difference of opinion.” Plaintiffs later amended to reduce damages to ₱100,000.00.
- The trial court in Magaspi treated damages as incidental but nevertheless ordered payment of under-assessed fees; the amendment superseded the original, and the court’s jurisdiction was upheld.
Issues:
- Whether the filing fee should be assessed based on the amount of damages alleged in the original complaint or the amended complaint.
- Whether underpayment of the docket fee deprives the trial court of jurisdiction.
- Whether the filing of an amended complaint specifying a lower amount of damages can cure any jurisdictional defect caused by the original underpayment.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)