Marcos, Heirs v. Presidential Commission on Good Government
REITERATIONFacts
The Antecedents: On February 28, 1986, Executive Order No. 1 created the Presidential Commission on Good Government (PCGG) to recover ill-gotten wealth amassed by former President Ferdinand E. Marcos and his associates. The PCGG was empowered to sequester businesses and entities controlled by them. In relation to these actions, the PCGG filed several civil cases, including those against former Ambassador Roberto S. Benedicto, an alleged crony of President Marcos. A compromise agreement was reached on November 3, 1990, between Benedicto and the Republic of the Philippines, wherein Benedicto surrendered 51% of his equity in Eastern Telecommunications Philippines, Inc. (ETPI), comprising 2,652,000 shares. Procedural History: The petitioners, claiming ownership of the shares ceded by Benedicto, filed a complaint with the Sandiganbayan on April 17, 1998, seeking a declaration of ownership, accounting, and damages. They paid a filing fee of P4,850.00. During the pre-trial conference on October 9, 1998, the Sandiganbayan raised concerns about the sufficiency of the docket fees paid, citing Section 7 of Rule 141 of the Revised Rules of Court and the doctrine that a court lacks jurisdiction without proper payment. The Sandiganbayan directed the petitioners to show cause why the complaint should not be dismissed for failing to pay the additional P1,326,955.00 in docket fees, based on the par value of the shares claimed. The petitioners argued that applying Rule 141 would unconstitutionally diminish their rights under PD 1606 and that Sections 4 and 5 of Rule 141, pertaining to the Court of Appeals, should apply. On February 15, 1999, the Sandiganbayan dismissed the case for lack of jurisdiction due to the failure to pay the correct filing fees. A motion for reconsideration was denied on May 24, 1999. The Petition: This petition for review on certiorari under Rule 45 of the 1997 Rules of Civil Procedure seeks to reverse the Sandiganbayan's resolution dismissing the petitioners' complaint. The petitioners contend that the Sandiganbayan erred in applying Section 7 of Rule 141 to its proceedings, arguing that this application is not supported by Section 4 of RA 7975 and would result in an unconstitutional application of Rule 141. They also argue that RA 7975 and RA 8249 did not repeal Section 11 of PD 1606, which provided for proceedings free of charge, and that Section 11 covers civil cases. Furthermore, they assert that Sections 4 and 5 of Rule 141, applicable to the Court of Appeals, should govern the filing fees, as the Sandiganbayan and the Court of Appeals are of the same level. The core issue is whether the Sandiganbayan erred in dismissing the case for non-payment of correct filing fees.
Issue(s)
Whether the Sandiganbayan erred in dismissing the petitioners' complaint for failure to pay the correct amount of filing fees. Whether the application of Section 7 of Rule 141 of the Revised Rules of Court to the Sandiganbayan is constitutional, and whether Section 11 of P.D. No. 1606 was impliedly repealed by R.A. Nos. 7975 and 8249. Whether Sections 4 and 5 of Rule 141 (Court of Appeals fees) should apply to the Sandiganbayan instead of Section 7. Whether the action has prescribed.
Ruling
The petition is unmeritorious. The assailed Resolution dated February 15, 1999, of the Fourth Division of the Sandiganbayan in Civil Case No. 0183, is hereby AFFIRMED.
Ratio Decidendi
On the dismissal for failure to pay correct filing fees and jurisdiction: The Court reiterated the rule that it is not merely the filing of the complaint or initiatory pleading, but also the payment of the prescribed docket fee, that vests a trial court with jurisdiction over the subject matter or nature of the action. The Sandiganbayan correctly dismissed the case for lack of jurisdiction due to the petitioners' failure to pay the proper amount of filing fees. The payment of docket fees is a jurisdictional requirement, and the court cannot exercise its jurisdiction until the correct fees are paid. The court may allow payment within a reasonable time, but not beyond the applicable prescriptive or reglementary period. On the application of Rule 141, Section 7 and the implied repeal of P.D. No. 1606: The Court held that Republic Act No. 7975 amended Section 9 of P.D. No. 1606 to state that the Rules of Court promulgated by the Supreme Court shall apply to all cases and proceedings filed with the Sandiganbayan. Consequently, Rule 141, Section 7(a) of the Rules of Court applies to complaints filed before the Sandiganbayan. The expansion of the Sandiganbayan's jurisdiction to include civil cases impliedly amended Section 11 of P.D. No. 1606, which provided that proceedings were to be conducted at no cost to the complainant. Therefore, parties filing civil actions before the Sandiganbayan are liable to pay the required docket fees. On the applicability of Court of Appeals fees (Sections 4 and 5 of Rule 141): The Court rejected the petitioners' contention that Sections 4 and 5 of Rule 141, pertaining to fees payable to the Court of Appeals, should apply to the Sandiganbayan because they are of the same level. While the Sandiganbayan might be considered of the same level as the Court of Appeals, it primarily functions as a trial court in cases like the one at bar. Its limited and exclusive appellate jurisdiction covers specific appeals from RTCs. Since the cognizance of the present case was in the exercise of its function as a trial court, Section 7 of Rule 141, which applies to legal fees payable to Regional Trial Courts, is the applicable provision. On prescription of action: The Court found that even if the right of action accrued on November 3, 1990, when Benedicto entered into the compromise agreement, or on September 10, 1993, when the compromise agreement was upheld, the ten (10)-year prescriptive period for actions based on constructive trust had already elapsed. The petitioners' repeated requests for extensions to file their reply, instead of addressing the issue of docket fees, demonstrated a failure to act within the prescriptive period. Therefore, prescription had set in, barring their right of action.
Main Doctrine
The payment of the prescribed docket fee is essential for a court to acquire jurisdiction over the subject matter or nature of an action. Failure to pay the correct amount of docket fees, especially when the claim involves recovery of property, can lead to dismissal for lack of jurisdiction, and may also be barred by prescription.