Title
Mijares vs. Ranada
Case
G.R. No. 139325
Decision Date
Apr 12, 2005
The Supreme Court ruled in favor of the petitioners, nullifying the orders of the RTC and reinstating the civil case, emphasizing the importance of recognizing and enforcing foreign judgments to protect the rights of the parties involved.
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Case Digest (G.R. No. 139325)

Facts:

  • Petitioners: Priscilla C. Mijares, Loretta Ann P. Rosales, Hilda B. Narcisco, Sr. Mariani Dimaranan, SFIC, and Joel C. Lamangan.
  • Respondents: Hon. Santiago Javier Ranada (Presiding Judge of Branch 137, RTC of Makati City) and the Estate of Ferdinand E. Marcos (represented by Imelda R. Marcos and Ferdinand Marcos, Jr.).
  • Origin: Class Action No. MDL 840 in the United States District Court of Hawaii.
  • Complaint: Filed on May 9, 1991, by ten Filipino citizens alleging human rights abuses during the Marcos regime.
  • US Judgment: Plaintiffs awarded $1,964,005,859.90 in damages, affirmed by the US Court of Appeals for the Ninth Circuit on December 17, 1996.
  • Enforcement in the Philippines: Petitioners filed a complaint with the Makati RTC on May 20, 1997.
  • RTC Dismissal: Due to non-payment of correct filing fees estimated to be approximately P472,000,000.00.
  • Petitioners' Argument: Claimed the action was not capable of pecuniary estimation, requiring only a minimal filing fee.
  • Subsequent Action: Petitioners filed a Petition for Certiorari under Rule 65 to annul the RTC's orders and reinstate their civil case.

Issue:

  • (Unlock)

Ruling:

  1. Pecuniary Estimation: The Supreme Court ruled that the action for the enforcement of a foreign judgment is capable of pecuniary estimation.
  2. Filing Fee: The Court nullified the RTC's orders a...(Unlock)

Ratio:

  • Enforcement of Foreign Judgment: The Supreme Court emphasized that the action's subject matter is the enforcement of a foreign judgment, which is capable of pecuniary estimation.
  • Filing Fee Calculation: Although the filing fee should be based on the value of the foreign judgment, the action against an estate and based on a judgment fell under Section 7(b)(3) of Rule 141, requiring only a minimal filing fee.
  • International Law: The Court highlighted the importance of recognizing and enforcing foreign judgments to protect the parties' rig...continue reading

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