GR 158090; (October, 2010) (Digest)
G.R. No. 158090; October 4, 2010
GOVERNMENT SERVICE INSURANCE SYSTEM (GSIS), Petitioner, vs. HEIRS OF FERNANDO F. CABALLERO, represented by his daughter, JOCELYN G. CABALLERO, Respondents.
FACTS
Fernando Caballero obtained a loan from GSIS, secured by a real estate mortgage over his property. Due to default, the mortgage was foreclosed in 1973, and GSIS consolidated ownership in 1975 after the redemption period lapsed. Years of negotiations for Caballero to repurchase the property failed. In 1989, GSIS scheduled a public bidding for the property. Caballero’s daughter submitted a bid of ₱350,000, but Carmelita Mercantile Trading Corporation (CMTC) won with a bid of ₱450,000. GSIS issued a resolution confirming the award to CMTC and executed a deed of absolute sale, leading to the issuance of a new title in CMTC’s name.
Caballero filed a complaint seeking to nullify the award and sale to CMTC, alleging irregularities in the bidding and asserting a prior right to repurchase. The Regional Trial Court (RTC) dismissed the complaint and granted GSIS’s counterclaim for ₱249,800 in rentals allegedly collected by Caballero from CMTC. The Court of Appeals (CA) affirmed the dismissal but deleted the award of rentals, finding that the RTC did not acquire jurisdiction over the counterclaim due to GSIS’s failure to pay the required docket fees.
ISSUE
Whether the Court of Appeals erred in deleting the award of rentals to GSIS based on the non-payment of docket fees for its compulsory counterclaim.
RULING
The Supreme Court denied the petition and affirmed the CA’s decision. The Court held that the counterclaim for unpaid rentals was compulsory in nature, as it arose from the same transaction—the foreclosure and subsequent occupancy of the property—that was the subject of Caballero’s complaint. Under Section 7, Rule 141 of the Rules of Court, as amended, the payment of prescribed docket fees is a jurisdictional requirement for all claims, including compulsory counterclaims. Jurisdiction over the counterclaim is only acquired upon full payment of the fees.
GSIS argued that the docket fee could be assessed later under the ruling in Sun Insurance Office, Ltd. v. Asuncion, which allows for subsequent determination of fees for unspecified damages. The Court found this inapplicable because the claim for a definite sum of ₱249,800 in accrued rentals existed at the time the answer was filed; it was not an unspecified or contingent claim arising after the complaint. Since GSIS did not pay the docket fee, the RTC never acquired jurisdiction over the counterclaim. The CA correctly deleted the monetary award. The Court emphasized strict adherence to the payment of docket fees as an essential step to vest jurisdiction.