G.R. No. 151242 ; June 15, 2005
PROTON PILIPINAS CORPORATION, AUTOMOTIVE PHILIPPINES, ASEA ONE CORPORATION and AUTOCORP, Petitioners, vs. BANQUE NATIONALE DE PARIS, Respondent.

FACTS

Petitioner Proton Pilipinas Corporation (Proton) availed of credit facilities from respondent Banque Nationale de Paris (BNP). Co-petitioners executed a corporate guarantee for the obligation. BNP and Proton subsequently entered into trust receipt agreements wherein Proton would hold imported vehicles in trust, sell them, and remit the proceeds to BNP, or return unsold vehicles. Alleging Proton’s failure to deliver proceeds or return vehicles, BNP demanded payment from the guarantors. Upon their refusal, BNP filed a complaint in the Makati RTC to recover the outstanding amount plus interest and attorney’s fees.
Petitioners moved to dismiss the complaint on grounds of failure to pay correct docket fees, arguing the court did not acquire jurisdiction. They contended the computation should exclude future interest. The Clerk of Court had assessed fees based on the total claim, including the principal sum and a fixed 5% attorney’s fee, converted to pesos at the prevailing exchange rate. The RTC denied the motion, holding the Clerk’s assessment was correct and, alternatively, that any deficiency could be paid within a reasonable time.

ISSUE

Whether the Regional Trial Court acquired jurisdiction over the case despite petitioners’ claim that the docket fees paid were insufficient.

RULING

Yes, the trial court validly acquired jurisdiction. The Supreme Court affirmed the Court of Appeals’ decision. The legal logic rests on the proper computation of docket fees under Rule 141 of the Rules of Court. For a purely monetary claim, the filing fee is computed on the aggregate amount claimed, exclusive of interest and costs. The Court clarified that the exclusion refers to interest that has yet to accrue at the time of filing. The principal amount claimed by BNP was a fixed sum, and the attorney’s fee, being a percentage of the principal demand, was correctly included in the base amount for computation. The Clerk of Court’s assessment, which used the prevailing exchange rate, is presumed regular and correct in the absence of contrary evidence.
Crucially, even assuming an initial underpayment, jurisdiction is not automatically forfeited. Following established doctrine, the court may allow payment of the deficiency within a reasonable time, and jurisdiction attaches upon full payment, barring prescription. The RTC did not find the paid fees insufficient and retained discretion to order a lien on any judgment award for any balance. Petitioners’ challenge was thus premature. The Court also found no merit in the ancillary claim of prematurity for lack of demand, as this is evidentiary, not a jurisdictional defect.