Facts:
On December 19, 1988,
Original Development and Construction Corporation (ODECOR) filed a complaint for
breach of contract and damages against
Home Insurance and Guaranty Corporation (HIGC),
National Home Mortgage Finance Corporation (NHMFC), and
Caloocan City Public School Teachers Association (CCPSTA) before Branch 171 of the
Regional Trial Court in Valenzuela, Metro Manila, docketed as Civil Case No. 3020-V-89. The allegations sought recovery for alleged acts of HIGC and NHMFC, including alleged delays and refusals in actions relating to housing project operations, which ODECOR claimed resulted in financial losses, deterioration of its market, and expenses. ODECOR prayed for actual, consequential, exemplary and moral damages “the amount of which will be proved at the trial,” and demanded attorney’s fees stated in the body of the complaint as “equivalent to 25% of the total money claims” excluding a trial honorarium. ODECOR also prayed that NHMFC be required to deliver and/or to pay the amount of
P2,272,193.10, which ODECOR asserted was due and payable and in NHMFC’s possession and custody. At the time of filing, ODECOR paid only filing-related amounts based on a “one numerical figure” stated in the complaint as
P2,272,193.10, while the rest of the claimed damages was not quantified, being left to later determination by the trial court. On March 4, 1989, HIGC moved to dismiss on the ground that the trial court did not acquire jurisdiction for failure to pay the proper docket fees, invoking
Manchester Development Corporation vs. Court of Appeals (149 SCRA 56 [1987]). NHMFC answered, CCPSTA was declared in default, and on June 1, 1989 the trial court denied the motion to dismiss and directed the Clerk of Court to issue a
certificate of reassessment to include any deficiency in docket fees, with a five-day period for payment; the order contemplated that where the judgment awards a claim not specified in the complaint or left for determination after trial, an additional filing fee would constitute a lien enforceable by the Clerk. The Clerk later reported that the deficiency could not be included because the attorney’s fees demand in the body had not been reiterated in the prayer, and the Clerk moved that the complaint be amended accordingly. HIGC then sought reconsideration, praying for dismissal or, alternatively, for amendment to reflect the specific amount of damages both in the body and prayer; the trial court denied the motion on June 29, 1989. ODECOR filed an amended complaint on July 6, 1989 specifying attorney’s fees as 25% of total monthly liability and other expenses of litigation and costs of the suit; it was admitted on July 11, 1989. Despite joinder of issues and the setting of the case for pre-trial conference, HIGC filed a petition for
certiorari questioning jurisdiction over the same ground of failure to pay proper docket fees, and the Court of Appeals restrained further proceedings. On July 31, 1990, the Court of Appeals held that the trial court did not acquire jurisdiction over Civil Case No. 3020-V-89, ordered the complaint expunged from the record, and declared the orders dated June 1 and 29, 1989 null and void for lack of jurisdiction. ODECOR sought reconsideration but later withdrew it and filed the present petition for certiorari, raising whether jurisdiction could be acquired even if the complaint did not specify the amount of damages.
Issues:
Whether the trial court acquired
jurisdiction over the case despite the complaint’s failure to specify the
amount of damages prayed for.
Ruling:
Ratio:
Doctrine: