GR 116121; (July, 2011) (Digest)
G.R. No. 116121; July 18, 2011
THE HEIRS OF THE LATE RUBEN REINOSO, SR., represented by Ruben Reinoso Jr., Petitioners, vs. COURT OF APPEALS, PONCIANO TAPALES, JOSE GUBALLA, and FILWRITERS GUARANTY ASSURANCE CORPORATION, Respondents.
FACTS
On June 14, 1979, a collision between a passenger jeepney owned by Ponciano Tapales and a truck owned by Jose Guballa occurred along E. Rodriguez Avenue, Quezon City, resulting in the death of jeepney passenger Ruben Reinoso, Sr. On November 7, 1979, the heirs of Reinoso (petitioners) filed a complaint for damages against Tapales and Guballa. Guballa filed a third-party complaint against Filwriters Guaranty Assurance Corporation (FGAC), his insurer. The Regional Trial Court (RTC) of Manila, Branch 8, rendered a decision on March 22, 1988, awarding damages to the petitioners, to Tapales, and to Guballa against FGAC. On appeal, the Court of Appeals (CA), in its Decision dated May 20, 1994, set aside the RTC decision and dismissed the complaint on the ground of non-payment of the correct docket fees pursuant to the doctrine in Manchester v. CA. The CA also ruled that prescription had set in, barring the petitioners from paying the required fees. The petitioners’ motion for reconsideration was denied.
ISSUE
Whether the Court of Appeals erred in dismissing the complaint based on non-payment of docket fees by retroactively applying the strict rule in Manchester v. CA.
RULING
Yes. The Supreme Court granted the petition and set aside the CA’s dismissal. The Court ruled that the strict application of the Manchester doctrine on mandatory payment of docket fees for jurisdiction should not be retroactively applied to this case, which was filed in 1979, prior to Manchester’s promulgation in 1987. Furthermore, the liberal doctrine established in Sun Insurance Office, Ltd. v. Asuncion, which allows payment within a reasonable time if there is no intent to defraud the court, should apply. The Court emphasized that the non-payment of docket fees was never raised as an issue before the RTC and was only motu proprio dismissed by the CA. Procedural rules should promote, not hinder, the administration of justice. Since the case was litigated on its merits in the RTC, and the petitioners demonstrated a willingness to abide by the rules, dismissal on a technicality was unwarranted. The case was remanded to the CA for resolution on the merits.