G.R. No. 226645 - Ramones vs. Spouses Guimoc

An Information was filed on June 30, 2006 before the Municipal Trial Court of Mariveles, Bataan (MTC), docketed as Criminal Case No. 06-8539.
The Information charged respondents, Teodorico Guimoc, Jr. and Elenita Guimoc, with the crime of Other Forms of Swindling under Article 316 (2) of the Revised Penal Code (RPC).
The accusatory portion alleged that on or about June 09, 2005, the respondents fraudulently obtained money (loan) amounting to P663,000.00 from petitioner Isabel G. Ramones with the promise to sell a house and lot.
It was further alleged that the respondents executed a Deed of Sale of Residential Building and Transfer of Rights, despite knowing that the property was already mortgaged to a third party, thereby causing damage and prejudice to petitioner.

Prior to the trial, the MTC Clerk of Court required petitioner to pay a docket fee of P500.00, as evidenced by a certification.
In a Judgment dated September 21, 2011, the MTC acquitted Teodorico Guimoc, but found Elenita Guimoc guilty beyond reasonable doubt of the crime.
The same Judgment ordered:

Elenita to pay P507,000.00 as her civil liability;
Teodorico, despite his acquittal, to pay P60,000.00 for his civil liability;
Both amounts were to accrue legal interest from December 13, 2006 until fully paid.

Respondents appealed the MTC decision to the Regional Trial Court (RTC), Criminal Case No. ML-4095.
In their Memorandum on Appeal filed on January 10, 2012, respondents argued that the MTC lacked jurisdiction to award damages, citing the failure of petitioner to pay the correct filing fees under SC Circular No. 35-2004.
The petitioner countered that under Rule 111 of the Rules of Criminal Procedure, actual damages are excluded from filing fee computation when a civil action is impliedly instituted with the criminal action.
In the RTC Judgment dated April 16, 2012, while acquitting Elenita on the ground of reasonable doubt regarding criminal liability, the court maintained the award of civil liabilities against respondents—even though it did not resolve the issue of the non-payment of proper filing fees.

The CA initially affirmed the RTC ruling and ordered payment of the civil liabilities.
Respondents later filed a motion for reconsideration, arguing that filing fees for actual damages should have been correctly assessed pursuant to SC Circular No. 35-2004.
On March 21, 2016, in its Amended Decision, the CA set aside the award of damages, deleting the order directing respondents to pay petitioner’s civil liabilities.
Petitioner’s subsequent motion for reconsideration was denied in a Resolution dated August 23, 2016.
Petitioner then elevated the issue to the Supreme Court by filing a petition for review on certiorari challenging the CA’s deletion of the civil award.

Whether the Court of Appeals correctly deleted the award of damages by relying on the alleged non-payment of the correct filing (docket) fees in the petitioner’s case.

The dispute centers on whether the P500.00 paid was sufficient, or whether the correct filing fee should have been based on the claimed amount of P663,000.00.
Whether the non-payment of the correct filing fees, as dictated by SC Circular No. 35-2004 and Section 21, Rule 141 of the Rules of Court, deprives the court of jurisdiction to award damages.

Whether the trial court’s jurisdiction was compromised by the underpayment of docket fees, given that requester later manifested willingness to pay any deficiency once assessed.

The issue also involves the application of Rule 111 of the Rules of Criminal Procedure, which exempts actual damages from the computation of the filing fee when a civil action is impliedly instituted.
Whether the doctrine of laches bars petitioner’s challenge due to the untimely raising of the alleged fee deficiency objection.

How the principles from relevant precedents (e.g., Manchester Development Corporation v. CA and Sun Insurance case) apply to the present controversy on fee assessment and jurisdiction.