Case Summary (G.R. No. 126749)
Relevant Facts
On November 15, 1993, Odilao initiated proceedings by paying a total of P25,600 in docket fees to the RTC in Southern Leyte. Following the payment, Suson filed a motion to dismiss the complaint based on improper venue, arguing that Odilao resided in Talisay, Cebu, not in Himonganan, Southern Leyte. The RTC granted the motion to dismiss on May 24, 1994, leading Odilao to re-file his complaint in the RTC of Cebu City. Upon the advice of RTC personnel, Odilao sought authorization from the Supreme Court through the Office of the Court Administrator to apply the previously paid docket fees to the new case.
Supreme Court Interaction
On July 12, 1994, Deputy Court Administrator Bernardo P. Abesamis responded favorably to Odilao's request, allowing him to re-file in Cebu City and present the previous receipts as proof of payment. Odilao then re-filed his complaint as Civil Case CEB-16336, and the court accepted it without requiring additional fees.
Procedural Developments
Following the acceptance of his complaint, Suson filed a motion to dismiss Civil Case CEB-16336, claiming that Odilao had not paid the appropriate docket fees. On September 16, 1994, the RTC rejected Suson's motion. The court emphasized the authorization provided by the Deputy Court Administrator and characterized the prior payment of fees as valid and relevant to the new filing.
Court of Appeals Ruling
Suson subsequently appealed to the Court of Appeals, which upheld the RTC's decision. The appellate court reasoned that requiring Odilao to pay anew the docket fee would infringe upon his constitutional right to access the courts for redress, as enshrined in Article III, Section 11 of the 1987 Constitution.
Legal Contentions
In his petition to the Supreme Court, Suson argued that allowing Odilao to utilize previously paid docket fees constituted a withdrawal of those fees and claimed that the new filing was a separate case requiring its own fees. Odilao countered that he was authorized only to apply previously paid fees to the newly filed case.
Relevant Jurisprudence
The Court cited the doctrines established in various rulings, emphasizing that a trial court acquires jurisdiction only upon payment of the prescribed docket fee. It noted that while the case might have been re-filed, it constituted a separate claim entirely from the dismissed one in Southern Leyte.
Decision of the Supreme Court
The Supreme Court ultimately ruled in favor of Suson,
...continue readingCase Syllabus (G.R. No. 126749)
Case Background
- This case is a petition for review on certiorari under Rule 45 of the Rules of Court.
- The primary issue revolves around whether a party whose complaint was dismissed by a Regional Trial Court (RTC) due to improper venue can seek authorization from the Supreme Court to re-file the complaint in the appropriate court without paying the required docket fee.
Procedural History
- The case originates from a civil suit for damages amounting to P5.15 million filed by private respondent David S. Odilao, Jr. against petitioner Eriberto M. Suson on November 15, 1993, in the RTC of San Juan, Southern Leyte.
- Odilao alleged that Suson made false accusations of graft and corruption against him, which damaged his reputation and caused him emotional distress.
- On December 17, 1993, Suson filed a motion to dismiss the complaint on the grounds of improper venue, asserting that Odilao resided in Talisay, Cebu, not in Southern Leyte.
- The RTC of Southern Leyte granted Suson's motion to dismiss on May 24, 1994.
Re-filing of the Complaint
- Following the dismissal, Odilao sought to re-file the complaint in the RTC of Cebu City.
- He initially presented proof of payment of the docket fees from the previous case to the Clerk of Court in Cebu City.
- On June 20, 1994, Odilao's counsel wrote to the Supreme Court's Court Administrator requesting authorization to apply the already paid docket fees to the new case in Cebu City.