Title
Spouses Algura vs. Local Government Unit of the City of Naga
Case
G.R. No. 150135
Decision Date
Oct 30, 2006
Spouses Algura sought indigent status after their property was demolished. SC ruled trial court erred in disqualifying them, emphasizing access to justice.

Case Digest (G.R. No. 71712)
Expanded Legal Reasoning Model

Facts:

  • Filing of Complaint and Indigency Motion
    • On September 1, 1999, spouses Antonio F. Algura and Lorencita S.J. Algura filed a Verified Complaint (dated August 30, 1999) for damages against the Local Government Unit of the City of Naga, its officers, and other respondents, alleging an illegal demolition of their residence and boarding house and claiming lost income of ₱7,000.00 per month from boarders.
    • Simultaneously, they filed an Ex-Parte Motion to Litigate as Indigent Litigants with:
      • Pay Slip No. 2457360 of Antonio Algura showing gross monthly income of ₱10,474.00 and net pay of ₱3,616.99 (July 1999).
      • Certification from the Office of the City Assessor of Naga City dated July 14, 1999, stating that the petitioners had no taxable property in their names.
  • Trial Court Proceedings
    • In a September 1, 1999 Order, RTC Branch 27, Naga City, granted the petitioners’ plea for exemption from filing fees.
    • On October 13, 1999, respondents filed an Answer with Counterclaim, asserting nuisance and road-right-of-way obstruction. Petitioners submitted a Reply with Request for Pre-Trial on October 19, 1999.
    • At pre-trial on February 3, 2000, respondents sought time to file a Motion to Disqualify the petitioners as indigent litigants. They filed such a motion on March 13, 2000, claiming the petitioners derived additional income from a sari-sari store, computer shop, and boarding house rentals.
  • Disqualification and Dismissal
    • On April 14, 2000, the RTC issued an Order disqualifying the petitioners as indigent litigants for failure to substantiate their exemption under Rule 141, Section 18 (applicable as of March 1, 2000) and directed payment of requisite filing fees.
    • Petitioners filed a Motion for Reconsideration on April 28, 2000, to which respondents objected on May 8, 2000.
    • On May 13, 2000, petitioners submitted compliance affidavits (their own and that of neighbor Erlinda Bangate) reiterating lack of sufficient income and real property.
    • On July 17, 2000, the RTC denied the Motion for Reconsideration, holding that Antonio’s gross income exceeded the ₱3,000.00 monthly threshold under Rule 141, Section 18.
    • On September 11, 2001, RTC Branch 27 dismissed Civil Case No. 99-4403 for non-payment of filing fees.

Issues:

  • Whether petitioners qualify as indigent litigants exempt from payment of filing fees under the 1997 Rules of Civil Procedure and applicable provisions on pauper/indigent litigants.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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