GR 165147; (July, 2008) (Digest)
G.R. No. 165147; July 9, 2008
PHILIPPINE FIRST INSURANCE CO., INC. and PARAMOUNT GENERAL INSURANCE CORPORATION, Petitioners, vs. PYRAMID LOGISTICS AND TRUCKING CORPORATION, Respondent.
FACTS
Respondent Pyramid Logistics filed a complaint for specific performance and damages against petitioners, its insurers, to recover the proceeds of two insurance policies covering lost goods valued at ₱907,149.07. In its prayer, Pyramid sought an order for petitioners to pay the insurance claims jointly and severally, plus attorney’s fees of ₱50,000.00 plus ₱1,500.00 per court appearance, and costs of suit. Based on the stated attorney’s fees in the prayer, the clerk of court assessed and Pyramid paid a docket fee of ₱610.00. Petitioners moved to dismiss the complaint on grounds of lack of jurisdiction due to non-payment of the correct docket fees. They argued that Pyramid deliberately omitted the principal claim of ₱907,149.07 from its prayer to evade paying the proper fee, citing the rule in Manchester Development Corporation v. Court of Appeals that damages must be specified in both the body and the prayer of the pleading for assessment of filing fees.
The Regional Trial Court (RTC) denied the motion to dismiss. The Court of Appeals affirmed the RTC, holding that while there was an underpayment, the trial court did not commit grave abuse of discretion as it retained authority to order payment of the deficiency during the proceedings. The appellate court found no intent to defraud the government.
ISSUE
Whether the trial court acquired jurisdiction over the complaint despite the alleged underpayment of docket fees.
RULING
Yes, the trial court acquired jurisdiction. The Supreme Court clarified that the ruling in Manchester—which mandated dismissal for failure to specify the amount of damages in the prayer—was intended to curb the deliberate intent to defraud the government of docket fees. This strict rule was subsequently relaxed in Sun Insurance Office, Ltd. v. Asuncion and Tacay v. Regional Trial Court of Tagum. The current doctrine is that a court acquires jurisdiction over a case even if the docket fee paid is insufficient, provided there is no intention to deceive. The court may allow the plaintiff to pay the deficiency within a reasonable time, and failure to do so may result in the dismissal of the case for non-payment of fees.
In this case, the Court found no evidence of a deliberate scheme by Pyramid to evade payment. The complaint explicitly stated the principal claim in its body. The error in assessment lay with the clerk of court, not with Pyramid, which paid the fee as assessed. The proper remedy was for the trial court to order payment of the deficiency, not to dismiss the case. Therefore, the RTC correctly denied the motion to dismiss and retained jurisdiction to direct the payment of the correct docket fee. The petition was denied.