Case Summary (G.R. No. 75919)
Key Dates
- Complaint filed: Prior to September 12, 1985
- Amended complaint filed: September 12, 1985
- Court En Banc resolution: May 7, 1987
Applicable Law
- 1987 Philippine Constitution (effective February 1987)
- Rules of Court on docket (filing) fees
- Precedent: Magaspi vs. Ramolete, 115 SCRA 193
Procedural Background
- Petitioners filed an original complaint alleging over ₱78 million in damages but omitted any specific amount in the prayer. They paid a docket fee of only ₱410, treating the action as one for specific performance “not capable of pecuniary estimation.”
- Upon the Court’s order, petitioners filed an amended complaint naming an additional co-plaintiff and deleting any damage amounts in the body. After further directive, they inserted a reduced damages figure of ₱10 million in the body—but still not in the prayer.
- The trial court admitted the amended complaint. The Court of Appeals ruled that the filing fee must be assessed on the damages alleged in the original complaint, not the amended one.
Nature of the Dispute
- Central Issue: Whether the filing fee must be computed based on the damages stated in the original complaint (₱78,750,000) or the amended complaint (₱10 million).
- Related Issue: Whether an honest difference of opinion over the correct docket fee can vest jurisdiction despite under-assessment.
Contention on Filing Fee Assessment
Petitioners, invoking Magaspi vs. Ramolete, argued that the filing fee should be based on the amended complaint’s specified damages. They contended that once the case had been filed and the amended complaint admitted, the amended allegations governed fee computation.
Comparative Analysis with Magaspi vs. Ramolete
- Magaspi involved an action for recovery of land possession with incidental damages. The trial court originally treated the damages as ancillary and levied a nominal fee. Upon amendment reducing damages, the Supreme Court held that the original honest misapprehension over fee did not oust jurisdiction; the amendment superseded and governed fee assessment.
- In contrast, the present case was clearly a combined action for tortious damages and specific performance. No honest difference of opinion could exist regarding its monetary nature, as over ₱78 million was plainly alleged.
Court’s Findings on Jurisdiction and Filing Fee
- Jurisdiction vests only upon payment of the correct docket fee based on the amount of damages prayed for.
- The trial court never acquired jurisdiction by virtue of the ₱410 payment, nor did the amended complaint or its fee regularize the defect.
- All proceedings after the under-assessment are null and void.
- The Court of Appeals correctly ruled that the original complaint’s damages govern the filing fee, not the amended pleading.
New Rule on Pleading Requirements and Filing Fees
- P
Case Syllabus (G.R. No. 75919)
Facts
- Petitioners filed an action for torts and damages, specific performance, and injunctive relief against respondents.
- Original complaint prayed for:
- Issuance of a writ of preliminary prohibitory injunction.
- Attachment of defendants’ properties sufficient to satisfy any judgment.
- Order directing defendants to execute a contract of sale and annul the illegal forfeiture of P3 million paid by plaintiffs.
- Joint and several liability of defendants for actual, compensatory, and exemplary damages, plus 25% thereof as attorney’s fees.
- Declaration of validity and effect of plaintiff’s tender of purchase price and conversion of injunction into a permanent one.
- The body of the complaint alleged damages totalling over P78,750,000; the prayer did not specify any amount.
Procedural History
- Upon filing, petitioners paid a docket fee of ₱410.00, treating the case as one for specific performance not subject to monetary estimation.
- The Supreme Court ordered an investigation into under-assessed filing fees; petitioners were granted leave to file an amended complaint.
- Amended complaint (Sept. 12, 1985):
- Added Philips Wire and Cable Corporation as co-plaintiff.
- Deleted any mention of the amount of damages in the body.
- Retained the original prayer without specifying damages.
- On October 15, 1985, the Supreme Court directed re-assessment of docket fees; the trial court ordered specification of damages in the amended complaint.
- Petitioners then specified damages at ₱10,000,000 in the body; still none in the prayer. The amended complaint was admitted.
- The Court of Appeals ruled that the filing fee must be based on the damages alleged in the original complaint.