Manchester Development Corporation v. Court of Appeals
ABANDONMENTFacts
The Antecedents: Petitioners filed an action for torts and damages and specific performance with a prayer for a temporary restraining order. The original complaint alleged over P78 million in damages in its body, but the prayer did not specify an amount for damages, only for injunctive relief and specific performance. The docket fee paid was P410.00, considering the action as merely one for specific performance where the amount involved is not capable of pecuniary estimation. Procedural History: The trial court admitted an amended complaint which included a co-plaintiff and omitted any mention of the amount of damages in the body of the complaint. Subsequently, upon order of the Supreme Court, the trial court directed the plaintiffs to rectify the amended complaint by stating the amounts they were asking for. The damages were then specified in the body of the amended complaint in the reduced amount of P10,000,000.00, but still no amount of damages were specified in the prayer. The amended complaint was admitted. The Petition: Petitioners sought reconsideration of a resolution, contending that the Court of Appeals erred in assessing the filing fee based on the original complaint's damages, citing Magaspi vs. Ramolete. They argued the fee should have been based on the amended complaint.
Issue(s)
Whether the Court of Appeals erred in assessing the filing fee based on the amount of damages sought in the original complaint. Whether the trial court acquired jurisdiction over the case despite the payment of an insufficient docket fee.
Ruling
The motion for reconsideration is denied for lack of merit. The Court of Appeals aptly ruled that the basis of assessment of the docket fee should be the amount of damages sought in the original complaint and not in the amended complaint. The trial court did not acquire jurisdiction over the case by the payment of only P410.00 as docket fee, and neither can the amendment of the complaint thereby vest jurisdiction upon the Court. Consequently, the order admitting the amended complaint and all subsequent proceedings and actions taken by the trial court are null and void.
Ratio Decidendi
On the assessment of the filing fee: The Court distinguished the present case from Magaspi vs. Ramolete. In Magaspi, there was an honest difference of opinion as to the nature of the action, which was primarily for recovery of ownership and possession, with damages treated as incidental. In the present case, the allegations, designation, and prayer clearly indicated an action for both damages and specific performance. The docket fee paid was obviously erroneous for considering the action as merely one for specific performance. The Court reiterated that the rule is well-settled that a case is deemed filed only upon payment of the docket fee, regardless of the actual date of filing. Therefore, the docket fee should be assessed by considering the amount of damages as alleged in the original complaint. On the acquisition of jurisdiction: The Court reiterated the principle that it acquires jurisdiction over any case only upon the payment of the prescribed docket fee. An amendment of the complaint or similar pleading will not thereby vest jurisdiction in the Court, much less the payment of the docket fee based on the amounts sought in the amended pleading. For legal purposes, there was no such original complaint that was duly filed which could be amended. Consequently, the order admitting the amended complaint and all subsequent proceedings and actions taken by the trial court are null and void. The ruling in Magaspi case, insofar as it is inconsistent with this pronouncement, is overturned and reversed.
Main Doctrine
The filing fee for a complaint must be assessed based on the amount of damages claimed in the original complaint, especially when the nature of the action clearly indicates it is for both damages and specific performance, and the omission of the damages in the prayer is intended to evade payment of correct fees. An amended complaint cannot vest jurisdiction upon the court if the original complaint failed to acquire it due to insufficient payment of docket fees.