Case Summary (G.R. No. 226645)
Facts of the Case
The case originated with an Information filed on June 30, 2006, in the Municipal Trial Court of Mariveles, Bataan (MTC), which alleged that the respondents conspired to defraud the petitioner by obtaining a loan of PHP 663,000.00 under the false promise of selling a house and lot already mortgaged to a third party. The MTC later found Elenita guilty, sentencing her to imprisonment and ordering civil liabilities, while Teodorico was acquitted but also held liable for a lesser amount.
Proceedings Before the RTC
Respondents appealed the MTC's decision, contesting the jurisdiction of the MTC based on alleged improper filing fee payments. They claimed the full amount of PHP 663,000.00 should have dictated the fees instead of the PHP 500.00 paid by Ramones. Conversely, Ramones argued her payment complied with Rule 111 of the Rules of Criminal Procedure, which does not require the payment of filing fees for actual damages when a civil action is implied within a criminal action.
RTC Judgment
In a judgment dated April 16, 2012, the Regional Trial Court (RTC) upheld the MTC's ruling with modifications, acquitting Elenita on reasonable doubt while maintaining the civil liabilities ordered against both respondents. Notably, the issue of the filing fee payments was not addressed in this ruling.
Appeal to the CA
The Court of Appeals (CA) affirmed the RTC's judgment on October 27, 2015, emphasizing that the non-payment of proper docket fees did not bar the recovery of damages. Respondents subsequently filed for reconsideration, leading to an Amended Decision on March 21, 2016, wherein the CA reversed its position. The CA ruled that the MTC erred in awarding damages due to the alleged improper payment of the filing fees.
Issue Before the Supreme Court
The core issue for the Supreme Court's resolution was whether the CA correctly removed the award of damages based on the appellant's arguments regarding the filing fees.
Court's Ruling
The Supreme Court determined that the petition was meritorious and that the RTC had indeed validly acquired jurisdiction over the case despite the insufficiency of the initial filing fee. Citing Rule 111, the Court reiterated that filing fees for actual damages are not required if the civil action is impliedly included within the criminal action. The finding referenced prior jurisprudence where courts maintained jurisdiction despite underpayment when there was no fraudulent intent.
Jurisdiction and Filing Fees
The Court established that the underspecified payment of PHP 500.00 was insufficient but noted that it was the amount assessed by the MT
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Case Background
- This case involves a petition for review on certiorari regarding the Amended Decision dated March 21, 2016, and the Resolution dated August 23, 2016, of the Court of Appeals (CA) in CA-G.R. SP No. 131201.
- The CA's decision annulled the Regional Trial Court of Bataan's (RTC) order for Spouses Teodorico Guimoc, Jr. and Elenita Guimoc to pay civil liabilities to petitioner Isabel G. Ramones.
Facts of the Case
- The case originated from an Information filed on June 30, 2006, accusing the respondents of Other Forms of Swindling under Article 316 (2) of the Revised Penal Code (RPC).
- The respondents allegedly obtained a loan of P663,000.00 from the petitioner with the promise to sell their mortgaged property, which they knowingly misrepresented.
- The Municipal Trial Court (MTC) in Mariveles, Bataan, found Elenita guilty and sentenced her accordingly, while acquitting Teodorico.
- Elenita was ordered to pay P567,000.00 in fines and P507,000.00 in civil liabilities, while Teodorico was ordered to pay P60,000.00.
- Both respondents appealed the MTC's ruling to the RTC, arguing the MTC lacked jurisdiction due to the petitioner’s alleged failure to pay the correct docket fees.
Proceedings Before the RTC
- The respondents contended that the petitioner did not pay the proper docket fee of approximately P9,960.00, claiming her payment of P500.00 was insufficient.
- The petitioner coun