Manchester Development Corporation, et al. v. Court Of Appeals, et al.

G.R. No. 75919, May 7, 1987

FACTS:
A complaint for specific performance was filed by Manchester Development
Corporation against City Land Development Corporation to compel the latter to
execute a deed of sale in favor Manchester. Manchester also alleged that City Land
forfeited the former’s tender of payment for a certain transaction thereby causing
damages to Manchester amounting to P78,750,000.00. This amount was alleged in
the BODY of their Complaint but it was not reiterated in the PRAYER of same
complaint. Manchester paid a docket fee of P410.00 only. Said docket fee is
premised on the allegation of Manchester that their action is primarily for specific
performance, hence it is incapable of pecuniary estimation. The court ruled that
there is an under assessment of docket fees hence it ordered Manchester to amend
its complaint. Manchester complied but what it did was to lower the amount of
claim for damages to P10M. Said amount was however again not stated in the
PRAYER.
ISSUE:
Whether the amended complaint should be admitted. (NO)
RULING:
The docket fee, its computation, should be based on the original complaint.
A case is deemed filed only upon payment of the appropriate docket fee regardless
of the actual date of filing in court. Here, since the proper docket fee was not paid
for the original complaint, it’s as if there is no complaint to speak of. As a
consequence, there is no original complaint duly filed which can be amended. So,
any subsequent proceeding taken in consideration of the amended complaint is
void.
Manchester’s defense that this case is primarily an action for specific
performance is not merited. The Supreme Court ruled that based on the allegations
and the prayer of the complaint, this case is an action for damages and for specific
performance. Hence, it is capable of pecuniary estimation.
Further, the amount for damages in the original complaint was already
provided in the body of the complaint. Its omission in the PRAYER clearly
constitutes an attempt to evade the payment of the proper filing fees. To stop the
happenstance of similar irregularities in the future, the Supreme Court ruled that
from this case on, all complaints, petitions, answers and other similar pleadings
should specify the amount of damages being prayed for not only in the body of the
pleading but also in the prayer, and said damages shall be considered in the
assessment of the filing fees in any case. Any pleading that fails to comply with
this requirement shall not bib accepted nor admitted, or shall otherwise be
expunged from the record.