Title
Ramones vs. Spouses Guimoc
Case
G.R. No. 226645
Decision Date
Aug 13, 2018
A case involving insufficient docket fees, where the Supreme Court upheld civil liabilities for swindling, applying good faith and estoppel by laches.

Case Summary (G.R. No. 113006)

Petitioner’s Allegation and Accusatory Portion

  • Charge: On June 9, 2005, respondents allegedly obtained from petitioner P663,000.00 by means of deceit — promising the sale of a house-and-lot and executing a Deed of Sale/Transfer of Rights despite knowledge that the property was mortgaged to a third person — constituting Other Forms of Swindling under Article 316(2) RPC.

Procedural Facts at Filing

  • Information filed June 30, 2006 before MTC (Criminal Case No. 06-8539).
  • MTC Clerk of Court assessed and petitioner paid P500.00 as docket fees; a certification of payment was later issued (certification dated April 11, 2016).
  • The Office of the Provincial Prosecutor of Bataan filed the Information.

MTC Judgment

  • Judgment dated September 21, 2011: Teodorico acquitted; Elenita found guilty beyond reasonable doubt and sentenced to imprisonment (one month and one day to four months arresto mayor) and a fine of P567,000.00 with subsidiary imprisonment. The MTC ordered Elenita to pay P507,000.00 and, despite his acquittal, Teodorico to pay P60,000.00 as civil liabilities, both with legal interest from December 13, 2006 until fully paid.

Appeal to the RTC and Contentions on Filing Fees

  • Respondents appealed to RTC (Criminal Case No. ML-4095). In their Memorandum on Appeal they contended the MTC lacked jurisdiction to award damages because petitioner paid only P500.00 instead of correct docket fees required by Supreme Court Administrative Circular No. 35-2004 (SC Circular No. 35-2004) implementing amendments to Rule 141 (A.M. No. 04-2-04-SC). They argued petitioner failed to reserve a separate civil action and thus filing fees should have been assessed on the P663,000.00 claimed (alleged correct fees around P9,960.00). Petitioner replied that under Rule 111 of the Rules of Criminal Procedure actual damages are excluded from filing-fee computation where the civil action is impliedly instituted with the criminal action.

RTC Ruling on Appeal

  • RTC Judgment dated April 16, 2012: affirmed MTC judgment with modification — acquitted Elenita on reasonable doubt but maintained respondents’ civil liabilities (P507,000.00 and P60,000.00). The RTC did not rule on the alleged non-payment of correct filing fees. Motion for reconsideration by Elenita denied May 21, 2013.

CA Proceedings and Reversal on Reconsideration

  • CA Decision dated October 27, 2015: initially affirmed RTC, holding that Rule 111 Section 1 does not require payment of filing fees for actual damages. Respondents moved for reconsideration.
  • CA Amended Decision dated March 21, 2016: on reconsideration, the CA set aside its earlier ruling and deleted the award of civil liabilities, holding that SC Circular No. 35-2004 was in effect at the time of filing and required payment of filing fees in estafa cases for civil claims unless the offended party manifested that the civil liability would be separately prosecuted. Accordingly, the CA ruled the award of damages was erroneous because the correct filing fees were not paid. Petitioner’s motion for reconsideration before the CA was denied by Resolution dated August 23, 2016.

Issue Presented to the Supreme Court

  • Whether the CA correctly deleted the award of damages on the ground that the trial courts lacked jurisdiction due to alleged underpayment of docket fees.

Governing Legal Provisions and Constitutional Basis

  • Applicable constitutional basis: 1987 Philippine Constitution (decision rendered in 2018).
  • Relevant procedural and statutory authorities: Rule 111, Rules of Criminal Procedure (Section 1: “no filing fees shall be required for actual damages”); Rule 141, Rules of Court (Section 21: fees collectible in estafa cases where offended party fails to manifest within 15 days that civil liability has been or will be separately prosecuted); A.M. No. 04-2-04-SC and SC Circular No. 35-2004 (guidelines revising allocation/assessment of legal fees under Rule 141); Section 2, Rule 141 (fees in lien; additional fees constitute lien on judgment). Relevant jurisprudence: Manchester Development Corp. v. CA (1987), Sun Insurance Office, Ltd v. Asuncion (1989), United Overseas Bank v. Ros and related cases applying liberal doctrine where deficiency resulted from clerk’s assessment and no fraud was shown; People v. Daud and Nacar v. Gallery Frames for interest rules.

Supreme Court’s Legal Analysis on Jurisdiction and Filing Fees

  • Fundamental rule: a court generally acquires jurisdiction only upon payment of the prescribed docket fee (Manchester). Manchester’s strict rule is rooted in fraud on the government; when plaintiffs intentionally attempt to evade fees, the court lacks jurisdiction.
  • Subsequent jurisprudence (Sun Insurance and later cases) tempered Manchester: where underpayment resulted from the clerk’s assessment and there was no intent to defraud, a more liberal approach applies — the clerk must determine any deficiency and require payment; if additional fees are due, the plaintiff must pay the deficiency, which will constitute a lien on any judgment.
  • The Court emphasized the distinction between (a) intentional evasion/fraud (Manchester rule applies) and (b) good-faith payment of fees as assessed by the clerk with willingness to pay deficiency (liberal doctrine applies). Prior cases (Rivera v. del Rosario; Fil-Estate Golf and Development, Inc. v. Navarro; United Overseas Bank v. Ros; Heirs of Reinoso, Sr. v. CA) demonstrate that when the amount paid equals the clerk’s assessment and there is no bad faith, jurisdiction is acquired subject to later payment of deficiency.

Application of Law to the Present Case

  • Facts: petitioner paid P500.00 as assessed by the MTC clerk; certification exists. Petitioner consistently manifested willingness to pay additional docket fees if required. There is no showing of fraud or intent to evade payment of correct fees. Respondents only belatedly raised the underpayment issue on appeal, having participated in MTC proceedings without timely objection.
  • The Court found no bad faith by petitioner and therefore applied the liberal doctrine: the trial courts acquired jurisdiction upon payment of the amount assessed by the clerk. Petitioner is required to pay any deficiency later assessed; such deficiency will constitute a lien on the monetary awards. The Court also invoked estoppel by laches to note respondents’ failure to time

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