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ERIBERTO M. SUSON v. CA

FACTS:

The case involves a petition for review on certiorari filed by petitioner Suson challenging the decision of the Court of Appeals dismissing his petition for certiorari. Private respondent Odilao filed a civil suit for damages against petitioner Suson before the RTC of San Juan, Southern Leyte, but the complaint was dismissed due to improper venue. Odilao then went to the RTC of Cebu City to re-file the same complaint, using the official receipts of the docket fees paid to the RTC of Southern Leyte as proof of payment. The Clerk of Court of the RTC of Cebu City allowed the re-filing of the complaint without requiring Odilao to pay anew the docket fees. Suson filed a motion to dismiss the re-filed complaint, arguing that Odilao did not pay the filing fee, but the RTC of Cebu City denied the motion to dismiss. The Court of Appeals upheld the decision of the trial court, holding that requiring Odilao to pay again the docket fee would unduly burden his constitutional right to free access to the courts. In his petition, Suson argues that relieving Odilao from paying the docket fee in the Cebu Court and allowing him to use the receipts from the Leyte Court is tantamount to withdrawing the docket fee paid to the Leyte Court. Odilao asserts that he was not granted an exemption from paying the filing fees but only an authority to apply the fees paid in the RTC of Southern Leyte as payment for the fees in the re-filed case in the RTC of Cebu City.

ISSUES:

  1. Whether the payment of the prescribed docket fee is a jurisdictional requirement.

  2. Whether the dismissal of the complaint due to improper venue in one court can be remedied by filing a new complaint in another court without the payment of the prescribed docket fee.

  3. Whether private respondent is exempt from paying the prescribed docket fee for filing a complaint.

  4. Whether the Office of the Court Administrator has the power to exempt parties from paying the prescribed docket fees.

RULING:

  1. The payment of the prescribed docket fee is a jurisdictional requirement. Filing fees are intended to take care of court expenses and the payment of said fees cannot be made dependent on the result of the action taken. A case is deemed filed only upon payment of the docket fee, regardless of the actual date of filing of the case in court.

  2. The dismissal of the complaint due to improper venue in one court does not automatically allow for the filing of a new complaint in another court without the payment of the prescribed docket fee. The plaintiff whose complaint was dismissed due to improper venue can still file another complaint, but this time in the court of proper venue. The court of proper venue will only acquire jurisdiction over the case upon payment of the prescribed docket fee.

  3. Private respondent is not exempt from paying the prescribed docket fee for filing a complaint. While Article III, Section 11 of the 1987 Constitution guarantees free access to the courts for all individuals, pauper-litigants are the only ones specifically exempted from paying court fees. Private respondent, not being a pauper-litigant, is therefore required to pay the prescribed docket fee.

  4. The Office of the Court Administrator does not have the power to exempt parties from paying the prescribed docket fees. The Office of the Court Administrator acts through the Court Administrator in the exercise of its administrative functions. The Court has laid down principles stating that no doctrine or principle laid down by the Court in an en banc decision may be modified or reversed except by the Court sitting en banc. Therefore, the Office of the Court Administrator does not have the authority to exempt parties from paying the prescribed docket fees.

PRINCIPLES:

  • The payment of the prescribed docket fee is a jurisdictional requirement.

  • A case is deemed filed only upon payment of the docket fee.

  • Dismissal of a complaint due to improper venue does not automatically allow for the filing of a new complaint without the payment of the prescribed docket fee.

  • The court of proper venue will acquire jurisdiction over the case upon payment of the prescribed docket fee.

  • Free access to the courts is guaranteed by Article III, Section 11 of the 1987 Constitution, but only pauper-litigants are exempted from paying court fees.

  • The Office of the Court Administrator acts through the Court Administrator in the exercise of its administrative functions.

  • No doctrine or principle laid down by the Court in an en banc decision may be modified or reversed except by the Court sitting en banc.