G.R. No. 86675 - MRCA, Inc. vs. Court of Appeals

Filing of the Complaint: The petitioner, MRCA, Inc., filed a complaint against the private respondents (Spouses Domingo Sebastian, Jr. and Lilia Tioseco Sebastian, and Expectacion P. Tioseco) in the Regional Trial Court (RTC) of Pasig, Metro Manila. The complaint sought moral damages, exemplary damages, attorney's fees, and litigation expenses, but the amounts were not specified in the prayer. Instead, the amounts were left "to the discretion of the court" or "to be proven during the trial."

Motion to Dismiss: The private respondents filed a motion to dismiss the complaint on July 15, 1988, invoking the Supreme Court's ruling in *Manchester Development Corporation vs. Court of Appeals* (149 SCRA 562). They argued that the failure to specify the amounts of damages in the complaint deprived the court of jurisdiction due to non-payment of the proper filing fees.

Trial Court's Decision: The RTC granted the motion to dismiss on August 10, 1988, agreeing with the private respondents' argument.

Appeal to the Court of Appeals: The petitioner appealed to the Court of Appeals, which upheld the RTC's decision on January 18, 1989.

Petition to the Supreme Court: The petitioner filed a petition for review under Rule 45 of the Rules of Court, arguing that the *Manchester* ruling should not apply retroactively because it had not yet been published in the Official Gazette when the complaint was filed. The petitioner also contended that there was no fraudulent intent to deprive the government of the proper filing fees.

Whether the *Manchester* ruling should apply retroactively to the petitioner's case.
Whether the failure to specify the amounts of damages in the complaint warrants the dismissal of the case for non-payment of the proper filing fees.
Whether the petitioner should be allowed to amend its complaint to specify the amounts of damages and pay the proper filing fees.