Ramones vs. Guimoc

A trial court acquires jurisdiction over a criminal case and its civil aspect when the offended party pays the docket fees as assessed by the Clerk of Court, even if such amount is subsequently found to be deficient, provided the party acts in good faith without intent to defraud the government; the deficiency shall constitute a lien on the judgment pursuant to Section 2, Rule 141 of the Rules of Court.

Petitioner Isabel G. Ramones extended a loan of P663,000.00 to respondents Spouses Teodoro Guimoc, Jr. and Elenita Guimoc on June 9, 2005, secured by a promise to sell their house and lot. Despite the property being already mortgaged to a third party, respondents executed a Deed of Sale of Residential Building and Transfer of Rights before a Notary Public to petitioner. When respondents failed to deliver the property or return the money, petitioner filed a criminal complaint for Other Forms of Swindling under Article 316(2) of the Revised Penal Code.

• On or about June 9, 2005, respondents obtained a loan of P663,000.00 from petitioner, promising to sell their house and lot to her as security.
• Respondents executed a Deed of Sale of Residential Building and Transfer of Rights over the property before a Notary Public, despite knowing the property was already mortgaged to a third person.
• On June 30, 2006, petitioner filed an Information for Other Forms of Swindling under Article 316(2) of the Revised Penal Code before the MTC.
• The MTC Clerk of Court assessed and required petitioner to pay docket fees of P500.00, which she paid on November 30, 2006, as evidenced by Official Receipt No. 3474417.
• On September 21, 2011, the MTC acquitted Teodorico but found Elenita guilty beyond reasonable doubt, sentencing her to imprisonment and ordering her to pay P507,000.00 in civil liability; Teodorico was also ordered to pay P60,000.00 despite his acquittal.
• Respondents appealed to the RTC, arguing for the first time that the MTC did not acquire jurisdiction because petitioner failed to pay the correct docket fees of approximately P9,960.00 as required by Supreme Court Administrative Circular No. 35-2004 for the P663,000.00 money claim.
• The RTC acquitted Elenita on reasonable doubt but maintained the civil liabilities, noting that the sale was executed as payment for a pre-existing loan without intent to defraud; the RTC did not rule on the docket fee issue.
• The CA initially affirmed the RTC, ruling that Section 1, Rule 111 of the Rules of Criminal Procedure does not require filing fees for actual damages, but reversed itself on reconsideration, deleting the civil liabilities based on the non-payment of correct docket fees under SC Circular No. 35-2004.
• Petitioner consistently manifested willingness to pay additional docket fees and claimed she paid the amount assessed by the Clerk of Court in good faith.

• Paid the full amount of docket fees as assessed by the MTC Clerk of Court, evidenced by a certification dated April 11, 2016, and consistently manifested willingness to pay any additional fees required.
• Cited Rule 111, Section 1 of the Rules of Criminal Procedure, which states that no filing fees are required for actual damages except as otherwise provided, and argued that the civil action was impliedly instituted with the criminal action.
• Asserted that the liberal doctrine in Sun Insurance Office, Ltd. v. Asuncion should apply because there was no intention to defraud the government, distinguishing the case from Manchester Development Corporation v. CA.
• Argued that respondents were estopped by laches from raising the jurisdictional issue belatedly on appeal after actively participating in the MTC proceedings for five years.

• Contended that the MTC did not acquire jurisdiction to award damages due to petitioner's failure to pay the correct amount of docket fees pursuant to Supreme Court Administrative Circular No. 35-2004 and Section 21, Rule 141 of the Rules of Court.
• Argued that for a claim of P663,000.00, the correct filing fees should have been approximately P9,960.00, not merely P500.00.
• Cited Manchester Development Corporation v. CA for the principle that a court acquires jurisdiction only upon payment of the prescribed docket fee.
• Asserted that petitioner failed to make an express reservation to separately institute a civil action, thereby requiring the payment of filing fees for the impliedly instituted civil action.

• Procedural: Whether the Court of Appeals correctly deleted the award of damages based on the alleged failure to pay the correct docket fees, and whether respondents were estopped by laches from raising the issue of jurisdiction.
• Substantive Issues: Whether the trial court acquired jurisdiction over the civil aspect of the criminal case despite the underpayment of docket fees, and whether the deficiency in filing fees constitutes a lien on the judgment.

• Procedural: The Supreme Court set aside the Amended Decision dated March 21, 2016 and the Resolution dated August 23, 2016 of the Court of Appeals. The Court held that the CA erred in deleting the award of damages. Respondents were estopped by laches from questioning the court's jurisdiction after actively participating in the proceedings before the MTC and belatedly raising the issue of underpayment only on appeal before the RTC, five years after the institution of the case.
• Substantive: The Court held that the trial court properly acquired jurisdiction over the case. While SC Circular No. 35-2004 and Section 21, Rule 141 required payment of filing fees in estafa cases, petitioner paid the full amount assessed by the Clerk of Court (P500.00) and demonstrated willingness to pay any deficiency without intent to defraud the government. Applying the Sun Insurance doctrine, jurisdiction is acquired when fees assessed by the clerk are paid, subject to the payment of deficiency. The deficiency shall constitute a lien on the judgment pursuant to Section 2, Rule 141. The Court ordered respondents to pay petitioner P507,000.00 (Elenita) and P60,000.00 (Teodorico) with legal interest, and directed the MTC to determine the deficient docket fees.

• Sun Insurance Office, Ltd. v. Asuncion Doctrine — Established that the strict Manchester rule applies only when fraud is committed on the government; where a party pays the filing fees as assessed by the clerk of court and demonstrates willingness to pay any deficiency, the court acquires jurisdiction subject to the payment of the deficiency assessment.
• Manchester Development Corporation v. CA Rule — The general rule that a court acquires jurisdiction over any case only upon the payment of the prescribed docket fee; strictly applied only in cases involving fraudulent evasion of docket fees.
• Estoppel by Laches — Defined as failure or neglect for an unreasonable and unexplained length of time to assert a right, warranting a presumption that the party entitled to assert it has abandoned it; a party cannot invoke jurisdiction to secure relief and later repudiate that jurisdiction.
• Lien on Judgment for Deficiency — Under Section 2, Rule 141 of the Rules of Court, where the court awards a claim, the party concerned shall pay additional fees which shall constitute a lien on the judgment in satisfaction thereof.

• "The Court acquires jurisdiction over any case only upon the payment of the prescribed docket fee."
• "When insufficient filing fees are initially paid by the plaintiffs and there is no intention to defraud the government, the Manchester rule does not apply."
• "Yet, where the plaintiff has paid the amount of filing fees assessed by the clerk of court, and the amount paid turns out to be deficient, the trial court still acquires jurisdiction over the case, subject to the payment by the plaintiff of the deficiency assessment."
• "Laches, in general sense, is failure or neglect, for an unreasonable and unexplained length of time, to do that which, by exercising due diligence, could or should have been done earlier; it is negligence or omission to assert a right within a reasonable length of time, warranting a presumption that the party entitled to assert it either has abandoned it or declined to assert it."
• "A party cannot invoke the jurisdiction of a court to secure affirmative relief against his opponent and, after obtaining or failing to obtain such relief, repudiate or question that same jurisdiction."

• Manchester Development Corporation v. Court of Appeals — Cited by respondents for the strict rule on docket fees; distinguished by the Court as involving fraudulent intent to evade payment.
• Sun Insurance Office, Ltd. v. Asuncion — Controlling precedent establishing that a liberal interpretation applies when parties pay fees assessed by the clerk and show willingness to pay deficiency without fraud.
• Rivera v. del Rosario — Cited to support the rule that jurisdiction is validly acquired upon payment of fees as assessed by the clerk of court.
• Fil-Estate Golf and Development, Inc. v. Navarro — Cited for the consistent ruling on jurisdiction acquisition when clerk-assessed fees are paid.
• United Overseas Bank v. Ros — Cited for the application of estoppel by laches to jurisdictional challenges raised belatedly.
• The Heirs of Reinoso, Sr. v. CA — Cited for the principle that jurisdiction is acquired when docket fees assessed by the clerk are paid.
• Tijam v. Sibonghanoy — Landmark case defining estoppel by laches applied by the Court.
• Lu v. Lu Ym — Cited for the proposition that the Manchester rule does not apply without intent to defraud.
• Fedman Development Corporation v. Agcaoili — Cited for the rule that jurisdiction is acquired despite deficient fees when the amount assessed by the clerk is paid.
• People of the Philippines v. Daud — Cited for the proper reckoning of legal interest in estafa cases (from filing of Information).
• Nacar v. Gallery Frames — Cited for the modification of interest rates (6% per annum from July 1, 2013).

• Article 316(2) of the Revised Penal Code — Defines Other Forms of Swindling (estafa) as the offense charged against respondents.
• Rule 111, Section 1 of the Rules of Criminal Procedure — Provides that except as otherwise provided, no filing fees shall be required for actual damages in criminal cases.
• Section 21, Rule 141 of the Rules of Court (as amended by A.M. No. 04-2-04-SC) — Requires payment of filing fees in estafa cases where the offended party fails to manifest separate prosecution of civil liability.
• Section 2, Rule 141 of the Rules of Court — Provides that deficiency in docket fees shall constitute a lien on the judgment.
• Supreme Court Administrative Circular No. 35-2004 — Guidelines requiring filing fees for money claims in estafa cases.

• N/A (Senior Associate Justice Antonio T. Carpio, Associate Justice Francis H. Jardeleza, and Associate Justice Mario V. Lopez concurred in the result without writing separate opinions; Associate Justice Alfredo Benjamin S. Caguioa was on wellness leave).