39. ISABEL G. RAMONES v. SPS. TEODORICO respondents' civil liabilities...

he RTC did not rule

GUIMOC, GR No. 226645, 2018-08-13 upon the issue of non-payment of correct filing
fees.
Facts:
In a Decision[25] dated October 27, 2015, the CA
This case stemmed from an Information[5] filed
affirmed the RTC judgment and order.[26] It
on June 30, 2006 before the Municipal Trial
ruled, among others, that the failure to pay
Court of Mariveles, Bataan (MTC), docketed as
docket fees did not preclude petitioner from
Criminal Case No. 06-8539, charging respondents
recovering damages, considering that Section 1,
with the crime of Other Forms of Swindling under
Rule 111 of the Rules of Criminal Procedure does
Article 316 (2) of the Revised Penal Code (RPC),
not require the payment of filing fees for actual
the accusatory portion of which reads:... fter the
damages.
said Information was filed by the Office of the
Provincial Prosecutor of Bataan to the MTC, the Issues:
latter's Clerk of Court wrote a letter[7] to
The issue for the Court's resolution is whether or
petitioner requiring her to pay the amount of
not the CA correctly deleted the award of
P500.00 as docket fees. After petitioner's
damages.
payment thereof,[8] a certification[9] was later
issued by the MTC Clerk of Court reflecting the Ruling:YES
same
Rule 111 of the Rules of Criminal Procedure
Eventually, the case proceeded to trial, and states that "[e]xcept as otherwise provided in
thereafter, the MTC, in a Judgment[10] dated these Rules, no filing fees shall be required for
September 21, 2011, acquitted Teodorico but actual damages."
found Elenita guilty beyond reasonable doubt of
the crime of Other Forms of Swindling under In the 1987 case of Manchester Development
Article 316 (2) of the RPC, and accordingly... Corporation v. CA (Manchester),[37] the Court
ordered her to pay a fine of P567,000.00 with laid down the general rule that "[a court] acquires
subsidiary imprisonment, as the case may be. In jurisdiction over any case only upon the payment
addition, Elenita was ordered to pay the amount of the prescribed docket fee."[38] In Manchester,
of P507,000.00, and despite his acquittal, the Court upheld the CA's dismissal of the case
Teodorico was also directed to pay the amount of filed therein, based on the following
P60,000.00, which amounts reflect their circumstances:
respective civil liabilities, both with legal interest The Court of Appeals therefore, aptly ruled in the
from December 13, 2006 until fully paid present case that the basis of assessment of the
Aggrieved, respondents appealed... respondents docket fee should be the amount of damages
argued that the MTC did not acquire jurisdiction sought in the original complaint and not in the
to award damages in favor of petitioner for failure amended complaint.
of the latter to pay the correct amount of docket
fees pursuant to Supreme Court Administrative
Circular No. 35-2004[14] (SC Circular No. 35-
2004), which provides that the filing fees must be
paid for money claims in estafa cases.
petitioner countered that based on Rule 111 of
the Rules of Criminal Procedure, actual damages
are not included in the computation of the filing
fees in cases where the civil action is impliedly
instituted with the criminal action, and the filing
fees shall constitute a lien on the judgment.[...
dated April 16, 2012, the RTC affirmed the MTC
ruling with modification, acquitting Elenita on the
ground of reasonable doubt, but still maintaining
40. Heirs of Dragon v. MBC. G.R. No. 205068, March 6,
2019
DOCTRINE:
               Under Rule 141, Section 1 of the Rules of
Court, filing fees must be paid in full at the time an
initiatory pleading or application is filed. Payment is
indispensable for jurisdiction to vest in a court.
FACTS:
               Dragon obtained several loans from Manila
Banking. Manila Banking was placed under receivership
by the Bangko Sentral ng Pilipinas. The bank’s receiver
sent Dragon several demand letters requiring him to pay
his outstanding loans, the final letter being dated August
12, 1998. In a Statement of Account attached to the
final letter, Manila Banking computed the amount
Dragon owed as P44,038,995.00, consisting of the
principal amount of P6,945,642.00, plus accrued
interest, penalties, and attorney’s fees as of July 31,
1998.
               Dragon failed to pay his outstanding obligation.
Thus, Manila Banking filed before the Regional Trial
Court a Complaint for collection of sum of money.
               RTC issued a Decision in Favor of Manila
Banking. Upon appeal, the CA affirmed RTC’S decision.
               NO. Under Rule 141, Section 1 of the Rules of
Court, filing fees must be paid in full at the time an
initiatory pleading or application is filed. Payment is
indispensable for jurisdiction to vest in a court.
The amount must be paid in full. Nonetheless, in
Magaspi v. Ramolete despite insufficient payment of
filing fees, a complaint for recovery of ownership and
possession was deemed docketed as there had been an
“honest difference of opinion as to the correct amount
to be paid.”
Unlike other cases, the amount of unremitted filing fees
here is substantial. Respondent paid only P34,975.75 in
filing fees based on its P6,945,642.00 claim alleged in its
Complaint. If respondent had properly stated the total
sum it claimed in its prayer, including the interests,
penalties, and charges, it should have paid P222,300.43,
as computed by the clerk of court. In effect, respondent
only paid 15.7% of the docket fees it owes the court.
Under the circumstances, a liberal application of the
rules on payment of filing fees is unwarranted. In
accordance with Manchester Development Corporation,
the Regional Trial Court did not acquire jurisdiction over
the Complaint due to respondent’s insufficient payment
of filing fees.

               Meanwhile, he Heirs of Dragon, represented by

Patricia Angeli D. Nubia, filed before this Court a Notice
of Death with Motion for Substitution of Petitioner and
a Motion for Extension of Time to File Petition for
Review under Rule 45. The Heirs of Dragon stated that
Dragon died on October 22, 2012. They further prayed
for an additional 30 days within which to file their
Petition for Review.

               Petitioners claim that Manila Banking concealed

the true amount it claimed to mislead the trial court’s
clerk of court and, thus, avoid paying the correct docket
fees. Petitioners argued that RTC lack jurisdiction for
failure to pay the filing fee in full.

ISSUE:

               Whether the Regional Trial Court had

jurisdiction over Manila Banking’s claims for interests,
penalties, and attorney’s fees despite its failure to pay
the correct docket fees

RULING:
41. NTC v. Heirs of Ebesa.