G.R. No. 205068. March 06, 2019
HEIRS OF RENATO P. DRAGON, REPRESENTED BY PATRICIA ANGELI D. NUBLA, PETITIONERS, VS. THE MANILA BANKING CORPORATION, RESPONDENT.

FACTS

From 1976 to 1982, Renato P. Dragon obtained several loans from The Manila Banking Corporation, evidenced by four promissory notes with a total principal of P6,945,642.00, plus stipulated interest, penalties, and attorney’s fees. The bank was placed under receivership in 1987. In 1998, the bank’s receiver sent Dragon a final demand letter, with a Statement of Account computing his total obligation at over P44 million, inclusive of accrued charges. Dragon failed to pay. Consequently, in 1999, Manila Banking filed a Complaint for collection, praying for judgment ordering Dragon to pay the principal sum of P6,945,642.00 “plus interests, penalties, and attorney’s fees computed up to the date of actual payment.”
Dragon raised defenses of payment, novation, and prescription. The Regional Trial Court ruled in favor of the bank but awarded only the principal amount plus stipulated interest and penalties from a 1998 date, rejecting the bank’s higher computed claim due to lack of supporting evidence. Dragon later raised, for the first time on a motion for reconsideration, the issue of the trial court’s alleged lack of jurisdiction due to the bank’s non-payment of the correct docket fees for its total monetary claim. Both the trial court and the Court of Appeals rejected this argument.

ISSUE

Whether the Regional Trial Court acquired jurisdiction over the case despite the plaintiff’s prayer for an indeterminate amount of interests and penalties beyond the principal sum stated in the complaint.

RULING

Yes, the trial court validly acquired jurisdiction. The Supreme Court clarified that the payment of the correct docket fees should not be contingent on the result of the case. The governing rule is that jurisdiction is based on the amount of the initial claim pleaded in the complaint, not on the amount finally adjudged. Here, Manila Banking’s complaint specifically prayed for the principal sum of P6,945,642.00. The additional phrase “plus interests, penalties, and attorney’s fees computed up to the date of actual payment” did not transform the claim into one for an unspecified or indeterminate amount. Such ancillary monetary claims are inherently dependent on the court’s determination and are not required to be specifically quantified in the pleading for jurisdictional purposes. The bank paid the docket fees corresponding to the principal claim. Following precedents like Sun Insurance Office, Ltd. v. Asuncion, a court acquires jurisdiction upon the filing of the complaint and payment of the prescribed fee based on the estimated claim. Any subsequent adjustment in the award does not affect the court’s jurisdiction. Dragon’s belated jurisdictional challenge, raised only after an adverse judgment, was correctly dismissed.