INTERCONTINENTAL BROADCASTING CORPORATION v. ROSE MARIE ALONZO LEGASTO

FACTS:

The petitioner, Intercontinental Broadcasting Corporation (IBC-13), entered into a Compromise Agreement with the private respondent, Antonio Salvador, to settle a sum of money case. The agreement stipulated that IBC-13 would pay P2,000,000.00 in staggered payments and offset airtime spots against a marketing fee due to IBC-13. The balance of the airtime spots would be valued at the prevailing market price and made payable upon demand. Both parties agreed to submit a motion to dismiss the case. The case was dismissed on July 4, 1998.

However, on December 18, 2000, IBC-13 filed a complaint to declare the Compromise Agreement null and void. Private respondent also filed a complaint for specific performance and damages. The two cases were consolidated and private respondent filed a motion for issuance of a writ of attachment.

IBC-13 then filed a motion to dismiss and/or suspend the proceedings, arguing that private respondent had not paid the correct docket fees. The trial court denied the motion, stating that the non-payment of docket fees did not divest it of jurisdiction. The Court of Appeals affirmed the trial court's ruling.

Petitioner filed a petition for review, but the Supreme Court held that jurisdiction was properly acquired and that the non-payment of docket fees did not divest the trial court of jurisdiction.

ISSUES:

  1. Whether the trial court acquired jurisdiction given the alleged non-payment of the correct docket fees.

RULING:

  1. The Supreme Court ruled that the trial court properly acquired jurisdiction over the case. The Court held that the petitioner's initial payment of the docket fees, though insufficient, did not divest the trial court of its jurisdiction, as there was no intent to defraud the government. This decision was based on the principle that any deficiency in filing fees could be addressed by making it a judgment lien on the awarded amount. The Clerk of Court or his duly authorized representative was directed to assess and collect the additional fees.

PRINCIPLES:

  1. Jurisdiction Acquisition by Payment of Docket Fees

    • Jurisdiction is vested upon the payment of the prescribed docket fee. If insufficient fees are paid initially, the court can allow payment of the deficiency within a reasonable time.
  2. Bad Faith in Docket Fee Payment

    • The Court does not apply the stringent requirements of the Manchester ruling where there is no intent to defraud the government and the party shows willingness to pay the correct fees within the prescribed period.
  3. Judgment Lien for Deficient Docket Fees

    • Additional filing fees assessed after a judgment awards claims not specified in the original pleading can constitute a lien on the judgment.
  4. Rule 141, Section 2 of the Rules of Court

    • This rule provides for the collection of additional fees when the court awards claims not alleged in the pleadings, with said fees constituting a lien on the judgment.