Chua v. Executive Judge, Metropolitan Trial Court, Manila
REITERATIONFacts
The Antecedents: Petitioner Richard Chua filed a complaint against Letty Sy Gan for forty (40) counts of violation of Batas Pambansa Bilang (BP Blg.) 22 before the Office of the City Prosecutor (OCP) of Manila. The OCP found probable cause and filed the corresponding forty (40) counts before the Metropolitan Trial Court (MeTC), Manila. Procedural History: The MeTC informed petitioner that the total filing fees amounted to ₱540,668.00. Petitioner, finding the amount beyond his means, inquired if he could pay on a per case basis, which was opined to be not allowed. Consequently, the cases were designated as undocketed cases (UDK Nos. 12001457 to 96) due to non-payment of filing fees. The OCP moved for consolidation. Petitioner filed an Urgent Motion to Allow Private Complainant to Pay Filing Fee on a Per Case Basis, which was denied by the Executive Judge on June 26, 2012, citing Section 1(b) of Rule 111 of the Rules of Court. A motion for reconsideration was also denied. The Petition: Petitioner filed a Petition for Review on Certiorari assailing the Orders of the Executive Judge.
Issue(s)
Whether the Executive Judge committed grave abuse of discretion in refusing petitioner's request to pay filing fees on a per case basis. Whether filing fees for multiple counts of violation of BP Blg. 22, filed from a single complaint and consolidated, can be paid on a per case basis.
Ruling
The petition is GRANTED. The assailed Orders dated June 26, 2012, and July 26, 2012, of the Executive Judge of the Metropolitan Trial Court, Manila, in UDK Nos. 12001457 to 96 are ANNULLED and SET ASIDE. The Metropolitan Trial Court, Manila, is directed to accept payments of filing fees in UDK Nos. 12001457 to 96 on a per information basis.
Ratio Decidendi
On the issue of grave abuse of discretion in refusing payment on a per case basis: The Supreme Court held that the Executive Judge committed grave abuse of discretion. The Court noted that petitioner was not attempting to evade his obligation but was merely acknowledging his inability to pay the entire amount at once and seeking to pursue some cases he could afford. The Executive Judge erred in treating the total amount as one indivisible obligation when it was merely the sum of individual filing fees for each count. Allowing payment on a per case basis would not constitute a deferment of payment, as the petitioner intended to pay for some cases. On the issue of whether filing fees for multiple counts of violation of BP Blg. 22, filed from a single complaint and consolidated, can be paid on a per case basis: The Court clarified that filing fees are assessed and become due for each initiatory pleading filed, which in criminal actions refers to the information. In this case, there were forty (40) counts of BP Blg. 22 violations, each assessed its individual filing fee. The filing of these counts is equivalent to filing forty (40) different informations, each representing an independent violation. Therefore, filing fees are due for each count and may be paid separately. The fact that all counts originated from a single complaint or were consolidated for trial is irrelevant to the assessment and payment of individual filing fees. Consolidation unifies cases for trial but does not transform the filing fees into one indivisible sum. While allowing payment for some cases would mean non-payment for others, the fate of those cases would be the concern of the MeTC.
Main Doctrine
The Executive Judge committed grave abuse of discretion in refusing to allow the petitioner to pay filing fees on a per case basis for forty (40) counts of violation of Batas Pambansa Bilang 22, as filing fees are assessed individually for each initiatory pleading, and consolidation does not transform these into one indivisible fee.