G.R. No. 139325 - Mijares vs. Ranada

On May 9, 1991, ten Filipino petitioners filed a class action in the U.S. District Court for the District of Hawaii under the Alien Tort Act, alleging arbitrary detention, torture, rape, summary execution and enforced disappearance by Philippine military or police between 1972–1987.
The U.S. court certified three subclasses (torture, summary execution, disappearance) totaling ~10,000 members, tried the case, and on February 3, 1995 awarded US$1,964,005,859.90 in compensatory and exemplary damages. The Ninth Circuit affirmed on December 17, 1996.

On May 20, 1997, petitioners filed in the Regional Trial Court (RTC) of Makati City a complaint to enforce the U.S. Final Judgment under Section 48, Rule 39, Rules of Court. They alleged the U.S. judgment had become final and executory.
The Marcos Estate moved to dismiss for non-payment of correct filing fees, contending that under Section 7(a), Rule 141, petitioners owed ~₱472 million instead of the ₱410 paid.
On September 9, 1998, RTC Judge Ranada dismissed the case without prejudice for failure to pay proper fees; he denied reconsideration on July 28, 1999.
Petitioners filed a Rule 65 certiorari petition with the Supreme Court, challenging the fee ruling as arbitrary, inequitable and violative of free access to courts (Sec. 11, Art. III, Constitution).

Is an action to enforce a foreign judgment “capable of pecuniary estimation” under Rule 141?
Which provision of Section 7, Rule 141 applies to such enforcement action against an estate?

Did the RTC commit a grave abuse of discretion in dismissing the complaint for non-payment of filing fees computed under the wrong Rule 141 provision?

Does requiring payment of exorbitant filing fees deny petitioners’ constitutional right to free access to courts due to poverty?