Dimaano v. Sandiganbayan
REITERATIONFacts
The Antecedents: Respondent Republic of the Philippines, through the Presidential Commission on Good Government (PCGG), confiscated cash and items from petitioner Elizabeth Dimaano, believing them to be ill-gotten wealth. The PCGG filed a forfeiture action, which was later dismissed by the Sandiganbayan, ordering the Republic to return the seized assets to Dimaano. This Court affirmed the Sandiganbayan's order. Procedural History: Dimaano filed a motion for the release of the seized assets, which the Sandiganbayan granted. Following the issuance of a writ of execution, the Bureau of Treasury released a check to Dimaano. However, the Sandiganbayan assessed Dimaano a sheriff's percentage collection fee of ₱163,391.50. Dimaano moved for reconsideration, arguing the fee was unwarranted as it applied only to actions for money covering collectibles or unsatisfied debts, not to the return of illegally confiscated money. The Sandiganbayan denied the motion, stating the fee assessment depended on the fact of collection, not the nature of the case. The Petition: Dimaano elevated the matter to the Supreme Court, questioning the propriety of the sheriff's percentage collection fee assessed on the money returned to her.
Issue(s)
Whether the Sandiganbayan rightfully assessed petitioner Elizabeth Dimaano a sheriff's percentage collection fee on the money that the Republic returned to her pursuant to the writ of execution. Whether petitioner Dimaano could still seek the award of interest on the amount to be returned, considering she did not appeal the Sandiganbayan's decision that did not mention interest.
Ruling
The Supreme Court affirmed the Resolutions of the Sandiganbayan dated July 25, 2006 and January 5, 2007, which assessed petitioner Elizabeth Dimaano a sheriff's percentage fee for the partial satisfaction of the writ of execution.
Ratio Decidendi
On the assessment of the sheriff's percentage collection fee: The Court held that the imposition of the sheriff's fee is not a penalty for any wrong committed by Dimaano but an assessment for the cost of the sheriff's service in collecting the judgment amount for her benefit. The fee is authorized under Rule 141 of the Rules of Court. The Court clarified that the order to pay a party the money owed to him and the order to pay another the money unlawfully taken from him are both awards of actual or compensatory damages, compensating for pecuniary loss. Both recipients benefit from the court's intervention and service in collecting the amount. Therefore, what determines the assessment of the disputed court fee is the fact that the court, through valid processes, ordered a certain sum of money to be placed in the hands of the sheriff for turnover to the winning party, regardless of whether the money was collected from a debtor or returned from an illegal confiscation. The Court emphasized that the rule does not distinguish between 'money collected' and 'money returned' when it comes to the sheriff's service fee. On the award of interest: The Court noted that Dimaano could no longer seek the award of interest because she had filed no appeal from the Sandiganbayan's decision that ordered merely the return of the amount without mention of interest. The Republic correctly pointed out this procedural bar to her claim for interest.
Main Doctrine
The sheriff's percentage collection fee is an assessment for the cost of the sheriff's service in collecting a judgment amount for the benefit of the winning party, and it applies to money ordered returned by a court through valid processes, not merely to money collected from a judgment debtor.