G.R. No. 226645 August 13, 2018
ISABEL G. RAMONES, Petitioner vs. SPOUSES TEODORICO GUIMOC, JR. and ELENITA GUIMOC, Respondents

FACTS

Petitioner Isabel Ramones filed a criminal case for Other Forms of Swindling under Article 316(2) of the Revised Penal Code against respondents Spouses Teodorico and Elenita Guimoc. The Information alleged that respondents, through deceit, obtained a loan of ₱663,000.00 from Ramones by promising to sell their house and lot, despite knowing the property was already mortgaged. The Municipal Trial Court (MTC) required Ramones to pay ₱500.00 as docket fees, which she paid. After trial, the MTC acquitted Teodorico but convicted Elenita, ordering her to pay a fine and, together with Teodorico despite his acquittal, to pay civil liabilities totaling ₱567,000.00 to Ramones.
On appeal, the Regional Trial Court (RTC) acquitted Elenita on reasonable doubt but affirmed the award of civil liabilities. Respondents argued before the RTC and later the Court of Appeals (CA) that the MTC never acquired jurisdiction to award damages because Ramones failed to pay the correct docket fees for her money claim, citing Supreme Court Administrative Circular No. 35-2004. The CA initially affirmed the RTC but, upon reconsideration, deleted the civil liability award, ruling that the payment of only ₱500.00 was a fatal deficiency in jurisdiction.

ISSUE

Whether the Court of Appeals correctly deleted the award of civil damages based on the alleged non-payment of the correct docket fees.

RULING

The Supreme Court reversed the CA and reinstated the civil liability award. The Court clarified that in criminal cases where the civil action for recovery of civil liability is impliedly instituted with the criminal action, no filing fees are required for actual damages under Section 1, Rule 111 of the Rules of Criminal Procedure. The exception under the amended Rule 141 and SC Circular No. 35-2004, which requires payment of fees for actual damages in estafa cases, applies only when the civil action is separately instituted or expressly reserved. Here, Ramones impliedly instituted the civil action with the criminal complaint; she did not file a separate civil action nor make a reservation. Consequently, the general rule under Rule 111 applies, and no filing fees for actual damages were required. The assessment and payment of ₱500.00 by the MTC Clerk of Court were sufficient for the criminal case. The deficiency in docket fees, if any, does not affect the court’s jurisdiction over the civil aspect impliedly instituted and merely constitutes a lien on the judgment award. Therefore, the lower courts correctly exercised jurisdiction in awarding civil liabilities arising from the crime.