Case Summary (G.R. No. 139325)
Issue on Filing Fees
Whether an enforcement action of a foreign judgment “against an estate based on judgment” is subject to the graduated fee schedule of Sec. 7(a) (computing fees on the sum claimed) or to the flat fee for “all other actions not involving property” under Sec. 7(b)(3) of Rule 141.
Nature of Enforcement Action
Enforcement of a foreign judgment is a civil action grounded not on the underlying torts but on the judgment itself. Jurisdiction to enforce lies with the regular courts, and the judgment operates as presumptive evidence of a right (Rule 39, Sec. 48). The only defenses are limited to lack of jurisdiction, notice, collusion, fraud, or clear mistake of law or fact.
Fee Schedule under Rule 141
- Section 7(a): Actions against an estate not based on judgment impose fees scaled to the sum claimed.
- Section 7(b)(1): Actions where the value cannot be estimated – P600.
- Section 7(b)(3): “All other actions not involving property” – P600.
The RTC applied Sec. 7(a), but that provision expressly excludes actions “based on judgment,” local or foreign.
Construction of Rule 141, Section 7
Because petitioners’ complaint is an enforcement of a foreign judgment (i.e., based on judgment), Sec. 7(a) does not apply. The proper classification is “all other actions not involving property,” Sec. 7(b)(3), entitling petitioners’ payment of P600 as filing fee.
Principles of Foreign Judgment Recognition
Under Rule 39, Sec. 48 and international comity, final foreign judgments of competent tribunals are recognized as presumptive evidence of rights, subject to specific defenses. Philippine law incorporates these generally accepted principles of international law (1987 Constitution, Art. II, Sec. 2). Conditioning enforcement on exorbitant fees contravenes the policy of preclusi
...continue readingCase Syllabus (G.R. No. 139325)
Background and Context
- Martial law (1972–1987) produced widespread human–rights abuses: torture, summary execution, disappearance.
- Petitioners are prominent victims who secured a U.S. class‐action award but lack direct access to former President Marcos.
- They seek recognition and enforcement of that foreign judgment against the Marcos Estate in Philippine courts.
Facts
- May 9, 1991: Ten Filipino citizens filed suit under the Alien Tort Act in U.S. District Court (Hawaii) against the Marcos Estate.
- Class certified under Fed. R. Civ. P. 23(a) & (b)(1)(B), divided into torture, execution, disappearance subclasses; ~10,000 members.
- Feb. 3, 1995: Final Judgment awarded US$1,964,005,859.90, affirmed by Ninth Circuit on Dec. 17, 1996.
- May 20, 1997: Petitioners filed a complaint in Makati RTC for enforcement under Section 50, Rule 39 of the Philippine Rules of Court.
Procedural History
- Marcos Estate moved to dismiss, alleging underpayment of docket fees: only ₱410 paid despite enforcement of over US$2.25 B.
- Petitioners contended that enforcement actions are not pecuniarily estimable; ₱410 correct under Rule 141, Sec. 7(c).
- Sept. 9, 1998: Respondent RTC judge dismissed complaint without prejudice, citing Sec. 7(a), Rule 141 and requiring ~₱472 M.
- July 28, 1999: Motion for Reconsideration denied; petitioners filed Rule 65 certiorari to annul both orders.
Issue
- Which provision of Rule 141 governs the filing fee for an action to enforce a foreign judgment against an estate?
- Is such an enforcement action “capable of pecuniary estimation” under Philippine procedural law?
Applicable Procedural Rules
- Rule 141, Sec. 7(a): Fees for money claims against an estate not based on judgment; computed per value of cl