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PROTON PILIPINAS CORPORATION v. BANQUE NATIONALE DE PARIS

FACTS:

In 1995, Proton Pilipinas Corporation (Proton) obtained credit facilities from Banque Nationale de Paris (BNP) and Proton's co-petitioners executed a corporate guarantee to secure Proton's obligations. Proton and BNP entered into trust receipt agreements, under which Proton would sell imported motor vehicles and deliver the proceeds to BNP. If the vehicles were not sold, Proton was obligated to return them to BNP. Proton allegedly failed to deliver the proceeds and return the unsold vehicles. BNP filed a complaint against the petitioners, seeking payment of the outstanding obligations. The defendants argued that BNP failed to pay the correct docket fees and that the complaint was premature. The Makati RTC denied the Motion to Dismiss, ruling that the docket fees were properly paid and that the absence of a demand letter was not a ground for dismissal. The ruling was affirmed by the Court of Appeals.

The petitioners argue that BNP failed to pay the correct docket fees as required by Administrative Circular No. 11-94. They contend that the interest claimed should have been included in the assessment of the docket fees. They also argue that the clerk of court used the wrong exchange rate in converting BNP's claims from US dollars to Philippine pesos. Furthermore, the petitioners claim that the complaint should have been dismissed for failure to specify the amount of interest in the prayer. They rely on a previous Supreme Court ruling condemning the practice of omitting the amount of damages in the prayer to evade paying the correct filing fees.

The case involves a dispute regarding the payment of the correct docket fees. The respondent argues that they have paid the filing fee as assessed and that there was no violation of Supreme Court Circular No. 7. The petitioner argues that the filing fee should be based on the amended pleading, which sought a higher amount of damages. The Supreme Court overrules a previous ruling and holds that the docket fee should be based on the amount claimed in the original complaint, not the amended pleading. The Supreme Court emphasizes the importance of strict compliance with the circular and orders it to be circulated to all courts and members of the Integrated Bar of the Philippines.

ISSUES:

  1. Whether or not the respondent has complied with Supreme Court Circular No. 7, which requires the payment of the proper docket and other legal fees.

  2. Whether or not the amount paid by the respondent as filing fee is correct.

  3. Whether the clerk of court correctly assessed the filing fee based on the total sum claimed

  4. Whether the failure to state the interest rate demanded in the complaint is fatal in determining the filing fee

  5. Whether the amounts claimed need to be initially stated with mathematical precision in order to determine the filing fee

  6. Whether the clerk of court correctly applied the exchange rate in determining the filing fee

  7. Whether the trial court acquired jurisdiction over the case despite the insufficient docket fees

  8. Whether a more liberal interpretation of the rules should be applied in determining the sufficiency of the docket fees.

  9. Whether the non-payment of the prescribed docket fee at the time of filing the complaint automatically results in the dismissal of the case.

  10. Whether the plaintiff can still claim damages not specified in the pleading without paying the additional filing fee.

RULING:

  1. No. The respondent failed to comply with Supreme Court Circular No. 7, which requires the payment of the proper docket and other legal fees. The said circular provides that the fees should be assessed based on the total sum claimed, inclusive of interest, damages of whatever kind, attorney's fees, litigation expenses, and costs, or the stated value of the property in litigation.

  2. No. The amount paid by the respondent as filing fee is incorrect. The correct amount should be computed based on Supreme Court Circular No. 7, which requires the inclusion of interest, damages, attorney's fees, litigation expenses, and costs in the computation of the fees.

  3. The clerk of court should have assessed the filing fee by considering the total sum claimed, inclusive of interest, damages, attorney's fees, litigation expenses, and costs, or the stated value of the property in litigation.

  4. The failure to state the interest rate demanded in the complaint is not fatal in determining the filing fee.

  5. The amounts claimed need not be initially stated with mathematical precision and can be subject to adjustment based on what is later proved.

  6. The presumption of regularity of the clerk of court's application of the exchange rate is disputable and can be overturned by sufficient evidence. In this case, the exchange rate of US $1 = P43.21 was proven with documentary evidence.

  7. Despite the insufficient docket fees, the trial court acquired jurisdiction over the case because the plaintiff demonstrated willingness to abide by paying the additional fees as required.

  8. A more liberal interpretation of the rules should be applied considering the plaintiff's willingness to pay the additional docket fees and the absence of a pattern and intent to defraud the government.

  9. The non-payment of the prescribed docket fee at the time of filing does not automatically cause the dismissal of the case, as long as the fee is paid within the applicable prescriptive or reglementary period and there was no intention to defraud the government.

  10. The plaintiff cannot claim damages not specified in the pleading without paying the additional filing fee. Any claim for damages arising on or before the filing of the complaint should be specified, and the determination of damages arising after the filing of the complaint is left to the discretion of the court.

PRINCIPLES:

  • Supreme Court Circular No. 7 requires the payment of the proper docket and other legal fees, which should be assessed based on the total sum claimed, inclusive of interest, damages of whatever kind, attorney's fees, litigation expenses, and costs, or the stated value of the property in litigation.

  • The correct amount of the filing fee should be computed in accordance with the provisions of Supreme Court Circular No. 7.

  • The filing fee should be assessed based on the total sum claimed, inclusive of various elements such as interest, damages, attorney's fees, litigation expenses, and costs, or the stated value of the property in litigation.

  • The failure to state the interest rate demanded in the complaint is not fatal in determining the filing fee.

  • The amounts claimed need not be initially stated with mathematical precision and can be subject to adjustment.

  • The presumption of regularity of the clerk of court's application of the exchange rate is disputable and can be overturned by sufficient evidence.

  • Despite insufficient docket fees, the court may acquire jurisdiction if the plaintiff demonstrates willingness to pay the additional fees as required.

  • A more liberal interpretation of the rules may be applied in determining the sufficiency of docket fees, especially if there is no pattern and intent to defraud the government.

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

  • Non-payment of the docket fee at the time of filing does not automatically lead to the dismissal of the case if paid within the applicable prescriptive or reglementary period and there was no intention to defraud.

  • Claims for damages arising before the filing of the complaint should be specified, and any damages arising after the filing of the complaint are subject to the determination of the court.

  • Forum shopping refers to the act of a party filing multiple suits in different courts, either simultaneously or successively, in order to obtain a favorable judgment.

  • Dismissal of a similar case filed in another court due to the plaintiff's failure to pay the correct filing fees does not necessarily indicate forum shopping.