GR 131530; (March, 2001) (Digest)
G.R. No. 131530; March 13, 2001
Y REALTY CORPORATION, petitioner, vs. HONORABLE SANDIGANBAYAN, 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 forfeiture case (Civil Case No. 0002) against the Marcoses and Prime Holdings, Inc. (PHI). Alfonso Yuchengco moved to intervene, claiming ownership over properties subject to forfeiture. His complaint-in-intervention was admitted. Later, Yuchengco sought to amend his complaint to implead the Cojuangcos and to include Y Realty Corporation, where he is the majority stockholder, as a co-plaintiff-in-intervention. The Cojuangcos and PHI moved to dismiss the amended complaint, arguing the Sandiganbayan lacked jurisdiction due to Yuchengco’s failure to pay the correct docket fees. They contended that since the action involved recovery of high-value shareholdings, substantial docket fees under Rule 141 of the Rules of Court were required.
The Sandiganbayan dismissed Yuchengco’s amended complaint-in-intervention for non-payment of the proper docket fees. This dismissal also effectively denied the pending joint motion by Yuchengco and Y Realty to admit their second amended complaint. Yuchengco elevated the dismissal to the Supreme Court in G.R. No. 131127. Y Realty, however, could not join that petition because it was not yet a formal party when the Sandiganbayan issued its resolutions, as its motion to intervene remained unresolved due to the dismissal of the underlying complaint.
ISSUE
Whether the Sandiganbayan correctly dismissed the amended complaint-in-intervention for non-payment of docket fees, thereby also barring Y Realty Corporation’s intervention.
RULING
The Supreme Court granted the petition, directing the Sandiganbayan to resolve the motion to admit the second amended complaint-in-intervention. The Court’s ruling in the related case, G.R. No. 131127 (Yuchengco v. Sandiganbayan), is controlling. In that decision, the Court held that while parties filing civil actions before the Sandiganbayan are generally liable to pay docket fees, the dismissal of Yuchengco’s complaint was improper. The Court set aside the dismissal and ordered Yuchengco to submit the value of the claimed properties and pay the corresponding docket fees within a set period.
Applying this precedent, the reinstatement of Yuchengco’s amended complaint upon payment of the correct fee removes the procedural obstacle that prevented the Sandiganbayan from ruling on the joint motion to admit the second amended complaint, which includes Y Realty. Since Y Realty’s interests are identical to Yuchengco’s and its intervention was contingent upon the viability of his complaint, the Sandiganbayan is now obligated to resolve the motion to admit with dispatch once the mandated docket fee is paid. The legal logic is that the defect in the original complaint was curable, and its cure revives the procedural platform for Y Realty’s inclusion.