Manchester Development Corp. v. Court of Appeals

Manchester Development Corporation sued City Land Development Corporation and others for torts, damages and specific performance, with a prayer for injunction and attachment, over the announced forfeiture of P3 million it had paid for property. The body of the complaint alleged damages totalling P78,750,000.00, but the prayer stated no amount, and only P410.00 was paid as docket fee on the theory that the action was merely for specific performance, an action not capable of pecuniary estimation. While an investigation of the under-assessment ordered by the Supreme Court was under way, the plaintiff, through new counsel, filed an amended complaint that added a co-plaintiff and deleted all mention of the amount of damages. When the trial court directed that the amounts be stated, the plaintiffs alleged P10,000,000.00 in the body, still not in the prayer, and the amended complaint was admitted. The Court of Appeals held that the docket fee should be assessed on the damages sought in the original complaint. Petitioners, relying on Magaspi v. Ramolete, moved for reconsideration of the Second Division's resolution; the case was referred to the Court En Banc.

1. 1Whether the docket fee should be assessed on the damages alleged in the original complaint rather than in the amended complaint.
2. 2Whether the trial court acquired jurisdiction over the case upon payment of only P410.00, and whether the amendment of the complaint could vest it.

Motion for reconsideration denied. The Court distinguished Magaspi v. Ramolete, where the underpayment arose from an "honest difference of opinion as to the correct amount to be paid as docket fee." Here no such difference was possible: the allegations, the designation and the prayer showed clearly an action for damages and specific performance, and the P78,750,000.00 spelled out in the body of the original complaint should have been the basis of assessment. Reiterating that "a case is deemed filed only upon payment of the docket fee regardless of the actual date of filing in court," the Court held that the trial court did not acquire jurisdiction by the payment of only P410.00, and the amendment could not vest jurisdiction because there was no original complaint duly filed that could be amended; the order admitting the amended complaint and all subsequent proceedings were null and void. The Court condemned counsel's omission of the amount from the prayer as intended to evade the correct fees and warned of drastic action on repetition. It ruled that henceforth all complaints, petitions, answers and similar pleadings should specify the amount of damages in both the body and the prayer, and any pleading that fails to comply shall not be accepted nor admitted, or shall otherwise be expunged from the record. It declared: "The Court acquires jurisdiction over any case only upon the payment of the prescribed docket fee," and overturned Magaspi insofar as inconsistent.