G.R. No. L-21707, March 18, 1967
FELIPE ACAR, ET AL., petitioners, vs. HON. INOCENCIO ROSAL, in his capacity as Executive Judge, Court of First Instance of Negros Oriental, 12th Judicial District, respondent.

FACTS

On February 21, 1963, ten individuals filed a class suit in the Court of First Instance of Negros Oriental on behalf of themselves and approximately 9,000 other farm laborers working in sugar cane plantations in the Bais milling district. The suit was against Compañia General de Tabacos de Filipinas, Central Azucarera de Bais, Compañia Celulosa de Filipinas, Ramon Barata, Aurelio Montinola, Sr., and Miguel Franco. The plaintiffs sought to recover their alleged shares, totaling P14,031,836.74, in sugar, molasses, bagasse, and other derivatives under Republic Act No. 809 (The Sugar Act of 1952), particularly Sections 1 and 9, which mandate the distribution of increased planter participation to laborers.
The plaintiffs, alleging they had no means to pay the docket fee of P14,500.00, filed a motion to sue as pauper litigants under Section 22, Rule 3 of the Rules of Court, invoking Section 1(21), Article III of the Constitution , which states: “Free access to the courts shall not be denied to any person by reason of poverty.” In support, they submitted certificates from municipal treasurers stating they had no real property declared in their names.
The respondent Judge denied the petition to litigate in forma pauperis on May 27, 1963, reasoning that the plaintiffs had regular employment and sources of income and thus could not be classified as poor or paupers. A motion for reconsideration was denied on June 11, 1963. The plaintiffs then filed a special civil action for certiorari and mandamus before the Supreme Court, which allowed them to litigate as paupers in the instant proceeding.

ISSUE

Whether the petitioners were deprived of free access to the courts by reason of poverty due to the denial of their motion to litigate as pauper litigants.

RULING

The Supreme Court granted the petition, declaring the petitioners entitled to litigate as paupers in their class suit and ordering the respondent Judge to grant their petition to litigate in forma pauperis.
The Court held that the respondent Judge erred in adopting a restrictive definition of “pauper” as “a person so poor that he must be supported at public expense.” The constitutional guarantee of free access to the courts and the rules on suits in forma pauperis require a broader interpretation. The term “pauper” in this context is synonymous with “indigent,” meaning persons who have no property or sufficient income for support aside from their own labor, even if they are employed and self-supporting when able to work. An applicant for leave to sue in forma pauperis need not be a public charge; it suffices that they lack the means to prosecute the action or secure costs.
The Court rejected the argument that the docket fee could be shouldered collectively by the 9,000 laborers, noting that the suit was a class action under Section 12, Rule 3 of the Rules of Court. Only the ten named plaintiffs were directly responsible for paying the docket fee, and even if the cost were spread among all laborers, it would amount to about P1.60 each—a substantial burden for seasonal farm laborers earning subsistence wages. This initial fee, along with subsequent legal costs, would effectively deny them access to the courts, contravening the constitutional mandate.
The Court found the supporting certifications of indigence adequate for the ten named plaintiffs, as a class suit does not require all members to be before the court. The petitioners were entitled to mandamus because they were excluded from the right to free access to the courts, and appeal was not an adequate remedy since they were not even accorded litigant status due to non-payment of the docket fee.
The decision aligns with the constitutional purpose of protecting individual rights and ensuring social justice, giving practical effect to the free access clause. No costs were awarded.