G.R. No. 169108 ; April 18, 2006
INTERCONTINENTAL BROADCASTING CORPORATION (IBC-13), Rep. by Its President Renato Bello, Petitioner, vs. HON. ROSE MARIE ALONZO LEGASTO and ANTONIO SALVADOR, Respondents.

FACTS

Petitioner IBC-13 and private respondent Antonio Salvador entered into a Compromise Agreement to settle a money claim, which was approved by the trial court. The agreement stipulated, among other things, that IBC would pay P2,000,000.00 and provide airtime spots. After IBC was privatized under new management, it filed an action to declare the Compromise Agreement null and void. Salvador, in turn, filed a complaint for Specific Performance and Damages to enforce paragraph 4 of the same agreement, which concerned the valuation of primetime airtime spots in the event of IBC’s privatization. The two cases were consolidated.
During the proceedings, Salvador filed a motion for a writ of attachment, revealing his claim was valued at P540,000,000.00 based on the airtime spots. IBC subsequently filed a motion to dismiss and/or suspend proceedings, arguing that Salvador’s action was actually a money claim, and the docket fees paid (P8,517.50) were grossly deficient. IBC contended the correct docket fee should be approximately P5.45 million, and thus the court lacked jurisdiction, or proceedings should be suspended until full payment.

ISSUE

Whether the trial court acquired jurisdiction over Salvador’s complaint despite the alleged gross deficiency in the payment of docket fees.

RULING

Yes, the trial court acquired jurisdiction. The Supreme Court affirmed the rulings of the Court of Appeals and the trial court, which denied IBC’s motion to dismiss. The Court reiterated the doctrine that a court acquires jurisdiction over a case upon the filing of the complaint and payment of the prescribed docket fee, regardless of any subsequent deficiency. Following the ruling in Sun Insurance Office, Ltd. v. Asuncion, where the nature of the action and the amount of the claim can be ascertained from the complaint, any deficiency in the docket fee does not automatically divest the court of jurisdiction. Instead, the unpaid fee constitutes a lien on the judgment award.
The Court found that Salvador’s complaint was primarily one for specific performance to enforce a contractual stipulation in the Compromise Agreement, not merely a simple action for a sum of money. The monetary claim for the value of the airtime spots was a necessary consequence of the primary relief sought. IBC’s active participation in the proceedings also estopped it from raising the jurisdictional issue belatedly. The trial court correctly ordered that any deficiency in docket fees would be treated as a judgment lien to be satisfied from any award, thereby protecting the interests of the judiciary without dismissing the case. The Clerk of Court was directed to assess and collect the additional fees.