Philippine National Bank v. Court of Appeals
REITERATIONFacts
The Antecedents: Private respondent Atty. Toribio R. Bella filed a suit for payment of attorney's fees based on quantum meruit before the Regional Trial Court (RTC) of Quezon City. The initial filing fee assessed was P 210.00. During trial, the private respondent declared his claim to be P 44,200,000.00, prompting petitioners to move for payment of the proper filing fee. This motion was denied by the RTC, ruling that the claim was based on quantum meruit. Procedural History: The Court of Appeals (CA) granted certiorari and prohibition, ordering the RTC to prohibit further hearing unless the correct filing fee was paid, remanding the case for recomputation based on 25% of the market value of the land involved in a prior case at P 400.00 per square meter. Under the rates in force at the time of filing (August 2, 1983), the fee would be P 89,000.00. However, new rates increasing the fees to P 178,164.00 took effect on October 1, 1984. Private respondent tendered P 89,000.00, which was refused. The RTC granted private respondent's motion to accept additional fees based on prevailing rates at the time of filing. Petitioners later filed a Motion for Clarification with the CA, seeking recomputation based on new rates, which was denied. Their motion for reconsideration was also denied, with the CA stating that 'correct filing fee' should be interpreted as the fee based on rates at the time of filing. The Petition: Petitioners filed a Second Motion for Reconsideration with the Supreme Court, claiming the CA Resolution of July 13, 1988, denying their petition, was erroneous. They argued that the Resolution reversed the Manchester case, which held that a complaint is not deemed filed until prescribed docket fees are paid. The Supreme Court noted that entry of judgment had been made and the motion was filed without leave.
Issue(s)
Whether the Second Motion for Reconsideration should be expunged from the records for being filed without leave of court and after entry of judgment. Whether the rates of docket fees prevailing at the time of the filing of the complaint or the new rates that took effect thereafter should be applied. Whether the Supreme Court's Resolution of July 13, 1988, erroneously reversed the ruling in the Manchester case, considering the good faith of the private respondent and subsequent jurisprudence on filing fees.
Ruling
The Supreme Court denied the Second Motion for Reconsideration with finality and affirmed the entry of judgment made on August 18, 1988. No further pleadings will be entertained.
Ratio Decidendi
On the procedural issue of the Second Motion for Reconsideration: The Court acknowledged that ordinarily, a second motion for reconsideration filed without leave of court and after entry of judgment should be expunged. However, the Court opted to dwell on the allegations made by the petitioners. This demonstrates a willingness to address substantive issues even when procedural rules might otherwise bar such consideration, provided there is a compelling reason or a claim of palpable error. On the application of docket fee rates: The Court ruled that the old rates, prevailing at the time the complaint was filed on August 2, 1983, should apply. The Resolution amending Rule 141 of the Rules of Court and prescribing new rates explicitly stated it would take effect on October 1, 1984. Therefore, the general rule that procedural statutes may be applied retrospectively does not apply here, as both the complaint filing and the motion for payment of correct filing fee occurred before the prescribed effectivity date of the new rates. This upholds the principle of applying the law in effect at the time of the commencement of the action. On the alleged reversal of the Manchester case and the relaxation of the rule regarding filing fees: The Court clarified that there was no error nor reversal of the Manchester case. The Manchester case involved a deliberate attempt to evade payment of correct filing fees, which the Court condemned as a fraudulent practice. In the present case, the Court of Appeals observed that the private respondent acted in good faith, believing that the filing fee would depend on the amount of the award in the final decision, as his claim was based on quantum meruit. This distinction in the parties' conduct and intent is crucial in differentiating the two cases. The Court noted that the ruling in the Manchester case has been relaxed by subsequent jurisprudence, specifically citing Sun Insurance Office Ltd. vs. Hon. Maximo C. Asuncion. In Sun Insurance, the Court reiterated that jurisdiction is acquired upon payment of the prescribed fee but allowed payment within a reasonable time. This indicates a more liberal approach to procedural technicalities concerning filing fees when substantial justice is at stake and there is no intent to defraud the court.
Main Doctrine
The rates of docket fees prevailing at the time of the filing of the complaint should be applied, even if new rates took effect thereafter, especially when the party acted in good faith and there was no deliberate attempt to evade payment.