Siapno v. Manalo
REITERATIONFacts
The Antecedents: The underlying dispute concerns the sale of a 31,159 square-meter real property owned by the National Tobacco Administration (NTA). Respondent Manuel V. Manalo offered to purchase the property, and his offer was accepted and approved by the NTA Board of Directors. A Deed of Sale was prepared, and Manalo made a downpayment and arranged for the balance. However, the petitioners, who were officials of the NTA, refused to finalize the sale, leading to the dispute. Procedural History: Manuel V. Manalo filed a petition for Mandamus with Damages against the petitioners in the Regional Trial Court (RTC) of Quezon City. Subsequently, Manalo filed an Amended Petition for Mandamus with Revocation of Title and Damages, impleading Stanford East Realty Corporation and seeking to nullify a sale to Stanford and seeking damages. The petitioners raised the defense that the amended petition was a real action and that proper docket fees were not paid, thus the RTC lacked jurisdiction. The RTC denied the petitioners' motion for a preliminary hearing on this defense, deeming the issue moot after Manalo paid additional fees. The petitioners then filed a petition for certiorari and prohibition with the Court of Appeals (CA), which dismissed their petition for lack of merit. This led to the present petition before the Supreme Court. The Petition: The petitioners are seeking a review on certiorari under Rule 45 of the Rules of Court, arguing that the Court of Appeals erred in upholding the RTC's jurisdiction. Their primary contention is that Manalo's amended petition was a real action, not a personal one, and thus required specific docket fees based on the property's value, which were not properly stated or paid. They also argue that Manalo deliberately omitted the amount of damages in the prayer of his original petition to evade correct filing fees, citing the ruling in Manchester Development Corporation vs. Court of Appeals. The petitioners assert that due to the deficient filing fees, the RTC never acquired jurisdiction, and consequently, the CA also acted without or in excess of jurisdiction in sustaining the RTC's orders.
Issue(s)
Whether the trial court acquired jurisdiction over the case given the alleged deficiency in docket fees. Whether the respondent's amended petition was a personal action or a real action. Whether the respondent's failure to specify damages in the prayer of his original and amended petitions warranted the dismissal of the case.
Ruling
The petition is GRANTED. The assailed decision of the Court of Appeals is REVERSED and SET ASIDE. Civil Case No. Q-95-24791 of the trial court is DISMISSED.
Ratio Decidendi
On the issue of jurisdiction and docket fees for damages: The Court reiterated its ruling in Manchester Development Corporation, et al. vs. Court of Appeals, emphasizing that any pleading failing to specify the amount of damages in both the body and the prayer shall not be accepted or admitted, or shall otherwise be expunged from the records. The Court noted that while Manalo's original petition alleged damages in the body, the prayer did not mention them. This practice is intended to evade payment of correct filing fees. The subsequent payment of additional filing fees by Manalo was deemed of no moment, as the original petition, suffering from this defect, should not have been admitted in the first place, rendering the amended petition without a valid existing petition to amend. Based on the foregoing, the Court concluded that the trial court never acquired jurisdiction over Civil Case No. Q-95-24791 due to the deficient payment of docket fees. Consequently, the appellate court, in sustaining the trial court's orders, also acted without or in excess of jurisdiction or with grave abuse of discretion. On the nature of the action as a real action: The Court held that Manalo's amended petition, which prayed for the annulment of the sale to Stanford and the declaration of nullity of Stanford's title, was, in essence, a suit to recover the real property in question and vest ownership and possession thereof in Manalo. Citing Fortune Motors (Phils.), Inc. vs. Court of Appeals and other cases, the Court stated that an action for annulment or rescission of a sale of real property is a real action whose prime objective is to recover said real property. The Court further noted that Manalo failed to allege the assessed value or estimated value of the property in his amended petition, which is required for computing the proper filing fee for a real action. On the consequence of failure to specify damages: The Court already addressed this in the first ratio, as it directly relates to the issue of jurisdiction and docket fees.
Main Doctrine
A pleading that fails to specify the amount of damages claimed in both the body and the prayer shall not be accepted or admitted, or shall otherwise be expunged from the record. Furthermore, an action to annul a sale of real property is a real action, requiring payment of docket fees based on the value of the property.