G.R. No. 165147 - Philippine 1st Insurance Co., Inc. vs. Pyramid Logistics and Trucking Corp.

Petitioners: Philippine First Insurance Co., Inc. and Paramount General Insurance Corporation.
Respondent: Pyramid Logistics and Trucking Corporation (formerly Panacor Integrated Warehousing and Trucking Corporation).
Pyramid filed a complaint for specific performance and damages seeking recovery of insurance proceeds under two policies:

On November 8, 2000, Pyramid’s delivery van loaded with goods (valued at PHP907,149.07) departed from the California Manufacturing Corporation (CMC) Bicutan Warehouse.
The van, together with its goods, disappeared; the driver and helper were untraceable.
Pyramid suffered damages and, after filing a criminal complaint for qualified theft against the missing personnel, claimed that petitioners as co-insurers were obligated to compensate.
Pyramid additionally alleged that it incurred expenses for legal services amounting to twenty-five percent of any recovery as attorney’s fees.

Pyramid’s original complaint did not specify in its prayer the exact claim amount corresponding to the lost goods, mentioning only a figure for attorney’s fees.
The docket fee was assessed at PHP610 based solely on the lesser amount (PHP50,000 for attorney’s fees), which Pyramid paid.
A first amended complaint was subsequently filed with only minor changes in the body but retaining the same incomplete prayer.

The alleged non-payment of the full requisite docket fee due to the omission in the prayer where the full value of damages (PHP907,149.07) was not stated.
The submission was argued to be deliberately crafted to lower the filing fee and, in effect, conceal the true nature of the claim.

The trial court denied the Motion to Dismiss despite noticing the omission, holding that in an action for specific performance the defect did not automatically warrant dismissal but limited the court to granting only what was properly prayed for.
Petitioners later filed a Petition for Certiorari before the Court of Appeals raising two issues:

Whether the underpayment (or mis-assessment) of docket fees deprived the trial court of jurisdiction.
Whether the case was truly an action for specific performance or merely an action for the recovery of money/damages.

The Court of Appeals partially granted the petition, setting aside portions of the trial court’s orders and requiring Pyramid to pay the correct docket fees within a reasonable time.
Pyramid filed comments and oppositions, arguing that the liberal rule (as seen in Sun Insurance Office, Ltd. v. Asuncion) should allow the payment of additional fees within the prescriptive period.
Subsequent motions for reconsideration by the petitioners and Pyramid’s responses were also considered in the appellate record.

Does Pyramid’s deliberate omission in its prayer to specify the full amount of its claims—and thereby paying a lower docket fee—affect the trial court’s jurisdiction over the case?
Is the trial court vested with jurisdiction if the initiatory pleading is accompanied by an under-assessed docket fee?

Is the case truly an action for specific performance (i.e., specific enforcement of the contractual insurance obligation) or is it effectively an action for the collection of a sum of money/damages?
How does the omission in the prayer, in light of the clear allegations in the body indicating a known monetary loss, affect the characterization of the claim?

What is the proper application of the rules laid down in Manchester Development Corporation v. Court of Appeals, specifically the requirement to state the claim amount for accurate docket fee computation?
How should the liberal rule from Sun Insurance Office, Ltd. v. Asuncion and subsequent cases be interpreted in allowing payment of additional fees within a reasonable period?

Does Pyramid’s strategy in drafting its complaint—omitting the specific claim amount—further suggest an intention to evade higher fees?
What are the ethical implications concerning the duty of lawyers to assist in the speedy and efficient administration of justice as reminded by the Court?