Case Summary (G.R. No. 208213)
Original Complaint and Docket Fee Dispute
Respondents filed Civil Case No. Q-05-56296 for quieting of title, annulment/cancellation of titles, and reconveyance, alleging adverse entry and destruction of houses and trees by petitioner and co-defendant Capitol Hills. They paid initial docket fees of ₱6,828.80 and executed an affidavit of undertaking for any deficiency. Petitioner moved to dismiss for underpayment, contending correct fees based on fair market value should be over ₱62 million.
RTC Denial of Dismissal and Issuance of TRO
The RTC denied the motion to dismiss and granted respondents’ request for temporary restraining order. Petitioner’s reconsideration motion asserted the 1978 tax declaration relied upon did not exist or correspond to the property.
CA’s First Review (CA-G.R. SP No. 99631)
The Court of Appeals denied petitioner’s certiorari petition, ruling jurisdiction once validly acquired by payment of assessed fees continues despite misassessment. It ordered the RTC Clerk to reassess correct docket fees under Rule 141 Sec. 7(a).
Supreme Court’s Entry of Finality and RTC Remand
On petitions G.R. Nos. 184376/184388, the Supreme Court affirmed the CA decision on January 19, 2009. The RTC, after remand, issued successive orders (Jan–May 2010) directing respondents to furnish tax declarations or zonal value information for fee recalculation and to pay additional fees, warning of dismissal for noncompliance.
Respondents’ Omnibus Motion and Claim of Indigence
On May 24, 2010, respondents moved to determine proper basis for fee computation (pre-taking market value vs. current value), to have additional fees constitute a lien, and to be declared indigent litigants unable to pay multimillion-peso fees. Petitioner opposed and later moved to dismiss for nonpayment and lack of jurisdiction.
RTC Resolution on Lien and Pauper Status
In August 2011, the RTC granted respondents’ omnibus motion, allowing additional fees as first lien on judgment and recognizing respondents as indigent litigants without property to satisfy fees. Petitioner’s motion for reconsideration was denied, and the Clerk was again ordered to reassess fees.
CA’s Ruling on Mootness (CA-G.R. SP No. 122999)
Petitioner filed certiorari before the CA, but the CA dismissed the petition as moot and academic in view of the May 4, 2012 RTC Order granting pauper litigant status. The CA nonetheless held any exempted fees shall remain a lien on any favorable judgment. Petitioner’s motion for reconsideration was denied.
Supreme Court’s Ruling on Mootness and Indigence Issue
The Supreme Court held the CA erred in declaring mootness becaus
...continue readingCase Syllabus (G.R. No. 208213)
Facts
- Respondents, alleged heirs of Lucas Lactao and Silvestra Aquino, filed Civil Case No. Q-05-56296 on September 9, 2005 for quieting of title, annulment and cancellation of titles, and reconveyance of possession over Lot 42-B-1, Pcs-13 (approx. 215,464 sqm) in Barangay Culiat, Caloocan.
- They alleged ancestral possession since World War II, subsequent forcible entry and destruction of houses and trees by petitioner Ayala Land, Inc. and Capitol Hills Golf and Country Club, Inc., and harassment by armed men hired by the defendants.
- Respondents applied for a temporary restraining order and writ of preliminary injunction to stop further land-grabbing.
- They initially paid ₱6,828.80 in docket fees and executed an Affidavit of Undertaking to secure any deficiency by a first lien on any future monetary award.
- Petitioner and Capitol Hills moved to dismiss, arguing prescription, laches, failure to state a cause of action, lack of jurisdiction due to underpayment of filing fees and failure to disclose fair market value of the property.
Procedural History
- The Regional Trial Court (RTC), Branch 58, denied the motion to dismiss and granted the TRO; petitioner’s motion for reconsideration was denied.
- Petitioner filed CA-G.R. SP No. 99631: the Court of Appeals (CA) (May 2, 2008) denied certiorari, held that jurisdiction was validly acquired despite underpayment, but ordered reassessment of the correct docket fees under Section 7(a), Rule 141 of the Rules of Court; its motion for reconsideration was likewise denied.
- Both sides sought review in the Supreme Court (G.R. Nos. 184376 & 184388); on January 19, 2009 the Court denied the petitions and their reconsiderations, rendering the CA decision final on June 16, 2009.
- The case was remanded to the RTC, which repeatedly directed respondents to provide tax declarations or zonal values for reassessment and to pay the recomputed fees. Respondents failed to comply.
- On May 24, 2010, respondents filed an Omnibus Motion asking (a) for a hearing on the basis of fee computation, (b) to declare their indigence and allow them to litigate as paupers, and (c) to make any additional docket fees a lien on the judgment. Petitioner opposed and moved to dismiss for failure to pay fees.
- RTC Branch 96 (August 18, 2011) granted respondents’ Omnibus Motion, held that additional fees could constitute a lien, recognized r