GR L 75919; (May, 1987) (Digest)
G.R. No. L-75919. May 7, 1987.
MANCHESTER DEVELOPMENT CORPORATION, ET AL., petitioners, vs. COURT OF APPEALS, CITY LAND DEVELOPMENT CORPORATION, STEPHEN ROXAS, ANDREW LUISON, GRACE LUISON and JOSE DE MAISIP, respondents.
FACTS
Petitioners filed a complaint for torts, damages, and specific performance with a prayer for a temporary restraining order. The body of the original complaint alleged damages totaling over P78 million, but the prayer did not specify any amount for damages, seeking only that defendants be ordered to pay “actual, compensatory and exemplary damages as well as 25% of said amounts as may be proved during the trial.” Upon filing, petitioners paid a docket fee of only P410.00, treating the action as one incapable of pecuniary estimation. When the Supreme Court, investigating similar under-assessment cases, ordered a re-assessment, petitioners filed an amended complaint deleting all mention of the amount of damages in the body. Following a trial court order to specify the amounts, petitioners filed another amended pleading stating damages of P10 million in the body but still not in the prayer.
ISSUE
Whether the trial court acquired jurisdiction over the case based on the original complaint and the initial payment of P410.00 as docket fee.
RULING
No. The Supreme Court, sitting En Banc, denied the motion for reconsideration and held that the trial court did not acquire jurisdiction. The ruling in Magaspi v. Ramolete, which allowed an amended complaint to cure a deficiency in docket fees arising from an “honest difference of opinion,” was distinguished and partially overturned. The Court found no honest difference of opinion here. The original complaint was clearly an action for damages, with a massive sum alleged in its body. The deliberate omission of the amount from the prayer was a transparent design to evade payment of the correct filing fees, a fraudulent practice compounded by the subsequent amendments intended to avoid the Court’s re-assessment order. Consequently, the payment of only P410.00 was grossly insufficient. Jurisdiction is vested only upon payment of the prescribed docket fee based on the amounts sought. An amendment cannot retroactively confer jurisdiction. The Court established a new mandatory rule: all pleadings must specify the amount of damages in both the body and the prayer, and this amount shall be the basis for assessing fees. Non-compliance will result in the pleading not being accepted or being expunged.