METROPOLITAN BANK v. BERNARDITA H. PEREZ

FACTS:

Petitioner Solidbank Corporation entered into a lease contract with respondent Bernardita H. Perez over two parcels of land in Bulacan. The lease contract was later terminated by Metrobank, the surviving entity after acquiring Solidbank. Respondent filed a complaint against Solidbank and Metrobank for breach of contract and damages. Metrobank argued that the lease contract did not prohibit pre-termination. After the respondent presented her case, Metrobank was declared to have waived its right to present evidence. The Regional Trial Court ruled in favor of the respondent and ordered petitioners to pay unrealized income, damages, attorney's fees, and litigation expenses. Metrobank appealed the trial court's decision and challenged the award of "unrealized income for the ensuing idle months" arguing that the complaint should have been dismissed for lack of jurisdiction due to non-payment of necessary docket fees. The appellate court affirmed the trial court's decision, stating that the respondent's failure to pay docket fees was justified because the period that the building would be idle could not be determined at the time of filing the complaint. The petitioner filed a petition for review on certiorari.

ISSUES:

  1. Whether or not the trial court had jurisdiction over respondent's claim for "unrealized income for the ensuing idle months" considering that she failed to pay docket fees for such claim.

  2. Whether or not respondent's failure to pay docket fees for the claim of "unrealized income for the ensuing idle months" results in the dismissal of her complaint.

RULING:

  1. The trial court had jurisdiction over respondent's claim for "unrealized income for the ensuing idle months" despite respondent's failure to pay docket fees. The possibility of the petitioner reconsidering its decision to terminate the lease contract and returning to the leased property was not definitively foreclosed when the complaint was filed. Therefore, it was justified for respondent to make a general prayer for the award of unrealized income for the "ensuing idle months" of the leased property.

  2. Respondent's failure to pay docket fees for the claim of "unrealized income for the ensuing idle months" does not result in the dismissal of her complaint. The Court held that a pleading which does not specify the amount sought shall not be admitted or shall be expunged. However, in this case, there were justifiable reasons for respondent's failure to pay additional docket fees. The possibility of the petitioner returning to the leased property was not foreclosed at the time the complaint was filed.

PRINCIPLES: