G.R. No. 131127 ; June 8, 2000
Alfonso T. Yuchengco, petitioner, vs. Republic of the Philippines, Presidential Commission on Good Government, Estate of Ferdinand E. Marcos, Prime Holdings, Inc., Estate of Ramon U. Cojuangco and Imelda O. Cojuangco, respondents.

FACTS

The Republic filed a complaint with the Sandiganbayan in 1987 to recover alleged ill-gotten wealth. Petitioner Alfonso Yuchengco, claiming ownership over some of the subject properties, filed a motion for intervention and a complaint-in-intervention in 1988, paying a docket fee of P400. The Sandiganbayan admitted the intervention. Years later, after Yuchengco amended his complaint to implead additional claimants, respondents Prime Holdings, Inc. and the Cojuangcos moved to dismiss the intervention. They argued the Sandiganbayan lacked jurisdiction because Yuchengco failed to pay the correct docket fees, as his complaint did not state the value of the massive shareholdings he sought to recover, violating the rule in Manchester Development Corporation v. Court of Appeals.
Yuchengco countered that under Section 11 of P.D. No. 1606, as amended, all proceedings in the Sandiganbayan should be conducted at no cost to the complainant, thus no docket fees were required. The Sandiganbayan dismissed Yuchengco’s amended complaint-in-intervention, ruling that the expansion of its jurisdiction to include civil cases made the payment of docket fees a jurisdictional requirement, and Yuchengco’s failure to pay the correct amount warranted dismissal.

ISSUE

Whether the Sandiganbayan correctly dismissed the complaint-in-intervention for alleged failure to pay the correct docket fees.

RULING

No. The Supreme Court partially granted the petition. The Court held that the Sandiganbayan erred in dismissing the complaint outright. While the Court affirmed that the payment of the prescribed docket fee is a jurisdictional requirement, it clarified that a complaint should not be dismissed for failure to comply with this requirement at the time of filing if the party demonstrates a willingness to abide by the rules. The ruling in Sun Insurance Office, Ltd. v. Asuncion modified the strict application of Manchester, allowing for the payment of the deficiency within a reasonable time as determined by the court, not warranting automatic dismissal.
The Court rejected Yuchengco’s argument based on Section 11 of P.D. No. 1606, ruling that the provision on free proceedings was intended for the original jurisdiction of the Sandiganbayan, which was exclusively criminal. Subsequent laws, like Executive Order No. 14 and Republic Act No. 7975 , expanded its jurisdiction to include civil forfeiture cases, thereby making the general rules on payment of docket fees applicable. However, the dismissal was too severe a penalty. The proper course was to direct Yuchengco to submit the value of the properties and pay the corresponding fees. The Sandiganbayan was ordered to determine the correct docket fees payable, and Yuchengco was given thirty days to pay the deficiency upon such determination.