Title
Ruby Shelter Builders and Realty Development Corporation vs. Formaran III
Case
G.R. No. 175914
Decision Date
Feb 10, 2009
Petitioner sought nullity of deeds executed as loan security, alleging pactum commissorium. SC ruled it a real action, requiring docket fees based on property value.

Case Summary (G.R. No. 175914)

Petitioner

Ruby Shelter Builders and Realty Development Corporation sought judicial annulment of five Deeds of Absolute Sale (dated January 3, 2006) and damages, asserting that the deeds were simulated or otherwise invalid, that acknowledgments were falsified, and that the transfers constituted an unlawful dacion en pago or pactum commissorium. Petitioner paid an initial docket fee of P13,644.25 when filing its complaint.

Respondents

Romeo Y. Tan and Roberto L. Obiedo loaned petitioner P95,700,620.00, took mortgages on the five parcels, agreed to a Memorandum of Agreement (MOA) condoning certain interest and permitting execution of Deeds of Absolute Sale as dacion en pago with redemption options, and later obtained TCTs in their names after the Deeds were notarized and presented to the Register of Deeds. Attorney Tomas A. Reyes notarized the MOA and Deeds.

Key Dates and Procedural Milestones

  • Memorandum of Agreement: March 17, 2005 (extended maturity and condonation terms).
  • Deeds of Absolute Sale: dated on records as January 3, 2006 (some documents showed January 2, 2006 in the MOA).
  • Deeds presented to Register of Deeds: March 8, 2006 (resulting in issuance of TCTs to Tan and Obiedo).
  • Complaint filed in RTC (nullity of deeds, damages, TRO/TRO request): March 16, 2006.
  • RTC Orders on docket fees: March 24 and March 29, 2006.
  • Court of Appeals Decision affirming RTC: November 22, 2006.
  • Supreme Court disposition: petition for review denied (decision rendered per caption).

Applicable Law and Legal Framework

Primary legal authorities considered: the 1987 Philippine Constitution (applicable given the decision date), the Rules of Court (Rule 45 for review on certiorari; Rule 141 governing clerks of court and docket/filing fees), A.M. No. 04-2-04-SC (revision to Rule 141 effective 16 August 2004), and Supreme Court Amended Administrative Circular No. 35-2004 (fee allocation guidelines). Controlling jurisprudence cited: Manchester Development Corp. (filing fee jurisdictional rule), Sun Insurance Office, Ltd. v. Asuncion (allowing reasonable time to pay fees), Gochan v. Gochan, Siapno v. Manalo, Serrano v. Delica, Spouses De Leon v. Court of Appeals, and related precedents addressing when an action for annulment/rescission of sale is a real action.

Factual Background and Contractual Terms

Petitioner obtained a large loan (P95,700,620.00) secured by mortgages on the five parcels. When petitioner defaulted, the parties executed a Memorandum of Agreement (MOA) providing, among other things: extension to settle indebtedness until 31 December 2005; condonation of specified interest, surcharges and penalties (figures in the MOA vary but total condoned amounts were stated in the record); contemporaneous execution of Deeds of Absolute Sale as dacion en pago to Tan and Obiedo with stated purchase prices and specified redemption prices (allowing petitioner to redeem individual or all parcels by paying specified sums); liquidated damages of P10,000,000.00 for any contest against the MOA/Deeds; and a personal joint-and-several monetary assumption by Ruben Sia in case of contest. The MOA and the Deeds were notarized by respondent Atty. Reyes. Petitioner alleges falsified acknowledgments and that respondents, with armed men, took physical possession and began demolition of improvements.

Reliefs Sought in the Complaint and Initial Filing

Petitioner filed a civil complaint seeking: an ex parte 72-hour TRO; preliminary injunction after notice and hearing; declaration of nullity of the MOA provision requiring deeds as dacion en pago as pactum commissorium; annulment of the five Deeds of Absolute Sale (dated January 3, 2006); actual, exemplary and other damages; attorney’s fees and costs. The action was docketed as Civil Case No. 2006-0030. The Clerk initially treated the complaint as an action “incapable of pecuniary estimation” and computed fees under Section 7(b)(1) of Rule 141 as amended.

Respondents’ Answer and Counterclaim

Only respondent Tan filed an answer admitting pre-filing meetings, denying falsification, asserting that the Deeds were the agreed consideration for extinguishing the indebtedness (with redemption option), and that petitioner failed to redeem. Tan alleged that Sia had confirmed his signature before the notary and counterclaimed for liquidated damages (P10,000,000.00) and other reliefs or, alternatively, for the loan balance and incidental expenses should the Deeds be invalidated.

Motion Regarding Proper Docket Fees

Respondent Tan filed an Omnibus Motion asserting that the complaint involves real property and therefore the docket fees must be computed under Section 7(a) (fees based on the fair market value of real property) rather than the flat rate under Section 7(b)(1) for actions incapable of pecuniary estimation. Tan argued that petitioner’s failure to pay the correct fee meant the RTC did not acquire jurisdiction.

RTC Orders Requiring Additional Fees and Computation

The RTC granted the motion and ordered petitioner (and Tan, with respect to his counterclaim) to pay additional fees computed under Section 7(a), Rule 141, as amended. The RTC adopted the reasoning that the action was akin to a quieting of title and therefore required fees under paragraph (a). The Clerk of Court later computed the additional fee due from petitioner (after crediting the initial payment) as P720,392.60. The RTC denied petitioner’s motion for partial reconsideration.

Court of Appeals Ruling

The Court of Appeals affirmed the RTC’s orders. It held that petitioner’s complaints sought not only annulment of the deeds but also ultimate recovery of the real properties (including cancellation of titles and recovery of possession), making the case a real action. Consequently, assessment and payment of fees under Section 7(a) were proper. The CA found no grave abuse of discretion by the RTC and rejected petitioner’s contention that the RTC’s application of Section 7(a) contradicted Spouses De Leon.

Legal Issue on Appeal to the Supreme Court

The sole assignment of error was that the Court of Appeals erred in affirming RTC orders requiring payment of additional docket fees under Section 7(a), Rule 141, contrary to the doctrine in Spouses De Leon that an action for annulment or rescission of a contract of sale of real property is incapable of pecuniary estimation.

Supreme Court’s Analytical Framework

The Supreme Court reaffirmed the settled rule that the nature of an action is determined by the allegations in the complaint but that, for accurate characterization, courts may consider pertinent facts disclosed in preliminary proceedings. The Court emphasized that where the relief sought, or the circumstances presented, manifest a plaintiff’s primary objective to recover title or possession of real property, the action is a real action, and Section 7(a) governs fee computation. The Court reviewed the record facts: the MOA was registered on the TCTs, the Deeds had been notarized and presented to the Register of Deeds resulting in issuance of titles to respondents, and respondents had taken possession and demolished improvements—facts petitioner failed to disclose in its complaint or to amend its pleading to reflect. Those facts supported classification as a real action.

Precedential Distinctions: Serrano, Gochan, Siapno, and Spouses De Leon

The Court applied and distinguished controlling precedents. In Gochan and Siapno, the Court held that actions seeking conveyance/transfer or revocation of title are real actions and require fee computation based on the property’s value; in Serrano the Court dismissed a complaint for failure to allege assessed/estimated value where cancellation and recovery of titles were sought. Spouses De Leon was distinguished because the complaint there sought solely annulment/rescission without transfer of title or possession to the adverse party and thus was truly incapable of pecuniary estimation. In contrast, the present case included transfer of titles and possession to respondents, aligning it with Serrano and the line requiring fees under the real-action metric.

Effect of Amendments to Rule 141 on Valuation

The Court noted that A.M. No. 04-2-04-SC amended Section 7 of Rule 141 by removing the specific paragraph that previously required the claimant to allege assessed or estimated value in the complaint; the amended provision prescribes using the fair market value of the real property as stated in the current tax declaration or current zonal valuation of the BIR (whichever is higher), or, if none, the stated value in litigation

    ...continue reading

    Analyze Cases Smarter, Faster
    Jur helps you analyze cases smarter to comprehend faster—building context before diving into full texts.