International Industrial Management v. Court of Appeals
REITERATIONFacts
The Antecedents: Private respondent Filipinas Carbon and Mining Corporation (FCAMC) filed an action for rescission or annulment of contract with damages against petitioner International Industrial Management and Development Corporation (INIMACO) and Central Mining Consultants (CMC) before the Regional Trial Court (RTC) of Manila. FCAMC sought various reliefs including rescission/annulment of an agreement, delivery of a mining area, and payment of actual, moral, exemplary damages, attorney's fees, and costs. Procedural History: FCAMC filed an amended complaint and subsequently a second amended complaint. INIMACO filed a motion to dismiss, arguing that the RTC did not acquire jurisdiction due to the alleged failure to state the amount of damages sought, rendering the docket fee undeterminable and unpaid. The RTC denied this motion. INIMACO then filed a petition for certiorari with the Court of Appeals (CA), which also denied the petition, finding that the claims for damages, qualified by "at least," were definite enough for jurisdiction and docket fee assessment, citing Ng Soon v. Hon. Aloysius Alday. The Petition: Before the Supreme Court, INIMACO sought an order directing the clerk of court of the RTC to reassess and collect the full prescribed docket fee, citing Sun Insurance Office, Ltd. v. Hon. Maximo C. Asuncion. INIMACO contended that the aggregate claims amounted to P29,600,000.00, requiring a docket fee of P118,000.00, of which only P2,626.00 was paid, leaving a balance of P115,374.00. FCAMC argued that its main action was for specific performance and/or rescission, which is not capable of pecuniary estimation, and the money claims were incidental, making the paid docket fee sufficient.
Issue(s)
Whether the Court of Appeals erred in upholding the trial court's denial of the motion to dismiss based on the alleged insufficiency of the docket fees paid, considering the nature of the claims and the definiteness of the damages sought. Whether the claims for damages in the second amended complaint are definite enough to determine the proper docket fees, and the implications of contingent or alternative reliefs on docket fee assessment. Whether the clerk of court should be ordered to reassess and collect the full prescribed docket fee, and the applicability of Sun Insurance Office, Ltd. v. Hon. Maximo C. Asuncion in this context.
Ruling
The petition is GRANTED. The clerk of court of the court a quo is instructed to reassess and determine the additional filing fee that should be paid by private respondent, considering the total amount of the claims sought in the second amended complaint as may be gleaned from the allegations and prayer thereof, and to require private respondent to pay the deficiency, if any.
Ratio Decidendi
On the sufficiency of damages claims for docket fee assessment and the Court of Appeals' decision: The Court reiterated that while the principal action for specific performance and/or rescission is not capable of pecuniary estimation and determines jurisdiction, separate claims for damages are not exempt from docket fees. The phrase "at least" used in quantifying damages renders the claims definite enough for assessing docket fees, consistent with Ng Soon v. Hon. Aloysius Alday. Therefore, the Court of Appeals did not err in finding that the trial court acquired jurisdiction. On the definiteness of damages claims and the computation of docket fees: The Court observed that the petitioner's computation of damages included contingent or alternative reliefs. However, it also identified specific unconditional claims for damages amounting to P3,450,000.00, which clearly required additional docket fees beyond what was paid. The instruction to the clerk of court to reassess would account for all collectible amounts based on the allegations and prayer in the second amended complaint. On the reassessment and collection of docket fees and the application of Sun Insurance Office, Ltd. v. Hon. Maximo C. Asuncion: Although the Court of Appeals correctly ruled on jurisdiction, the Supreme Court found it appropriate to grant the petitioner's prayer for reassessment and collection of the deficiency in docket fees, as was done in Sun Insurance Office, Ltd. v. Hon. Maximo C. Asuncion. The Court found it appropriate to apply the ruling in Sun Insurance, where it was held that if the initiatory pleading is not accompanied by the payment of the docket fee, the court may allow payment within a reasonable time but not beyond the applicable prescriptive or reglementary period. This precedent supports the directive to reassess and collect any deficiency in the docket fees paid by the private respondent.
Main Doctrine
Claims for damages, even if incidental to a principal action for rescission or specific performance, are subject to the payment of docket fees. The phrase 'at least' in stating damages renders the claim definite enough for docket fee assessment, with provisions for refunds or additional payments.