GR 76119; (April, 1989) (Digest)
G.R. No. 76119, April 10, 1989
PILIPINAS SHELL PETROLEUM CORPORATION, CALTEX (PHILIPPINES) INC., AND MOBIL OIL PHILIPPINES, INC., petitioners, vs. THE COURT OF APPEALS, HON. ESTHER NOBLES BANS, Presiding Judge, Branch LXXI, Zambales and Olongapo City, and ADRIAN S. DELA PAZ, respondents.
FACTS
Private respondent Adrian dela Paz, holder of a patent for “Coco-diesel fuel,” filed a complaint for patent infringement and damages against several oil companies, including petitioners. The complaint did not specify the amount of damages claimed but alleged the defendants’ combined annual gross sales from the invention were approximately P934 million. During a hearing, private respondent explicitly testified that his estimated yearly royalty claim was P236,572,350.00. Petitioners discovered that only a minimal filing fee of P252.00, based on a claim for attorney’s fees, had been paid.
Petitioners moved to dismiss the complaint for non-payment of the correct docket fees. The Regional Trial Court denied the motion but ordered private respondent to pay an additional docket fee of P945,636.90, computed from his stated monetary claim. Upon private respondent’s motion for reconsideration, the trial court modified its order, allowing him to pay the required additional fee after the prosecution of the case, to be deducted from any judgment award. Petitioners’ challenge to this modified order was dismissed by the Court of Appeals, prompting this petition.
ISSUE
Whether a trial court may allow a plaintiff, who is not a pauper-litigant and who can state the amount of damages claimed, to defer the full payment of the prescribed docket fees until after the trial.
RULING
No. The Supreme Court reversed the Court of Appeals and reinstated the trial court’s original order for immediate payment. The ruling is anchored on the principle that payment of the prescribed docket fee is a jurisdictional requirement. It is the payment, not merely the filing of the complaint, that vests the trial court with jurisdiction over the subject matter.
The Court applied the rules clarified in Sun Insurance Office, Ltd. v. Asuncion, which reconciled prior jurisprudence. A court may allow payment of the fee within a reasonable time if not paid upon filing, but it cannot defer such payment indefinitely until after judgment, especially when the claimant has specified the amount sought. Here, private respondent quantified his claim during testimony, thereby fixing the basis for the correct fee. His right of access to courts is not impaired, as the Rules provide a remedy for indigents through a pauper-litigant application. Since he did not claim indigency, he must pay the fees as assessed to confer jurisdiction upon the court. The case was remanded to the trial court, with proceedings to resume only upon full payment of lawful fees or upon a proper grant of pauper status.