GR 96724; (March, 1991) (Digest)
G.R. No. 96724 ; March 22, 1991
HONESTO GENERAL, petitioner, vs. HON. GRADUACION REYES CLARAVALL, Judge, Regional Trial Court at Pasig, Br. 71, BENNETH THELMO and the PEOPLE OF THE PHILIPPINES, respondents.
FACTS
Private respondent Benneth Thelmo filed a sworn complaint for libel with the Public Prosecutor, alleging he suffered damages totaling P100 million. An information for libel was subsequently filed with the Regional Trial Court (RTC). This criminal information, however, did not contain any allegation regarding the amount of damages claimed by Thelmo. During trial, petitioner Honesto General objected, arguing that Thelmo could not pursue the civil action for damages because he had not paid the corresponding docket fees for his P100 million claim.
The RTC overruled the objection, prompting General to file a petition for certiorari with the Supreme Court. He contended that under the doctrines established in Manchester v. CA, Sun Insurance v. Asuncion, and Tacay v. RTC, the payment of filing fees for the civil liability is a jurisdictional prerequisite for its implied institution with the criminal action. He argued the trial court committed grave abuse of discretion in allowing the civil action to proceed without such payment.
ISSUE
Whether the offended party must first pay the docket fees corresponding to his claim for damages for the civil action to be deemed validly impliedly instituted with the criminal action.
RULING
The Supreme Court dismissed the petition, upholding the RTC’s orders. The Court clarified the application of the Manchester doctrine, which required payment of filing fees corresponding to claimed damages for a court to acquire jurisdiction, in relation to civil actions impliedly instituted with criminal prosecutions under Rule 111 of the Rules of Court.
The legal logic hinges on the 1988 amendments to Section 1, Rule 111. The rule distinguishes between two scenarios. First, if the complaint or criminal information specifically alleges the amount of damages other than actual damages, then the corresponding filing fees must be paid upon the filing of the case in court for trial. Second, if the amount of such damages is not alleged in the complaint or information, then the payment of filing fees is not a prerequisite. Instead, the fees shall constitute a first lien on any judgment award. The Court explained that the intent was to curb the abuse of claiming astronomical damages in criminal complaints to harass the accused without paying fees, while not penalizing parties who do not specify amounts in the formal charge.
In this case, since the Information filed in court did not allege any specific amount of damages, the second scenario applied. Therefore, Thelmo was not required to pay filing fees upfront to pursue his civil action for damages impliedly instituted with the criminal libel case. The trial court correctly overruled the objection, as its order was in strict accord with the amended procedural rule.