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ISABEL G. RAMONES v. SPS. TEODORICO GUIMOC

FACTS:

The respondents, Spouses Teodorico Guimoc Jr. and Elenita Guimoc, were charged with the crime of Other Forms of Swindling for obtaining a loan from the petitioner, Isabel G. Ramones, by promising to sell their house and lot to her even though they knew the property was already mortgaged. The Municipal Trial Court (MTC) acquitted Teodorico but found Elenita guilty and ordered her to pay a fine and civil liability. The respondents appealed to the Regional Trial Court (RTC), which affirmed the MTC's ruling but did not rule on the issue of non-payment of correct filing fees. On their appeal, the respondents challenged the payment of filing fees, claiming that the petitioner's payment of P500.00 was insufficient. Initially, the Court of Appeals (CA) affirmed the RTC's judgment, stating that the failure to pay docket fees did not prevent the petitioner from recovering damages. However, after reconsideration, the CA granted the respondents' motion and removed the award of damages, referring to SC Circular No. 35-2004. Dissatisfied with this decision, the petitioner filed a petition for review on certiorari before the Supreme Court (SC) to challenge the CA's ruling.

ISSUES:

  1. Whether the court a quo acquired jurisdiction over the case despite the insufficient payment of filing fees.

  2. Whether the petitioner acted in good faith and had no intention to defraud the government.

  3. Whether the respondents are required to pay additional filing fees for the relief granted by the court.

  4. Whether the respondents are barred from questioning the jurisdiction of the court on the ground of laches.

  5. Whether or not the respondent committed Grave Misconduct, Dishonesty, and Conduct Prejudicial to the Best Interest of the Service.

  6. Whether or not the respondent should be dismissed from service.

RULING:

  1. The court a quo properly acquired jurisdiction over the case despite the insufficient payment of filing fees. The court ruled that when there is underpayment of docket fees, the clerk of court or his duly authorized deputy has the responsibility of making a deficiency assessment, and the party filing the action would be required to pay the deficiency which shall constitute a lien on the judgment. As long as there was no intention to defraud the government, the court acquires jurisdiction upon the full payment of the docket fees as assessed by the clerk of court.

  2. The petitioner acted in good faith and had no intention to defraud the government. The petitioner consistently manifested her willingness to pay additional docket fees when required. She immediately went to the clerks of court and paid the amount assessed from her. The petitioner's actuations negate any bad faith and intent to defraud the government.

  3. Yes, the respondents are required to pay additional filing fees for the relief granted by the court. Pursuant to Section 2, Rule 141 of the Rules of Court, when the court awards a claim or relief different from that claimed in the pleading, the party concerned shall pay the additional fees. It is the duty of the clerk of court to assess and collect these fees.

  4. Yes, the respondents are barred from questioning the jurisdiction of the court on the ground of laches. The respondents actively participated in the proceedings before the trial court and only raised the issue of alleged underpayment of docket fees on appeal to the higher court, five years after the institution of the case. The doctrine of estoppel by laches applies in this case as the respondents cannot invoke the jurisdiction of the court to secure affirmative relief and later question the same jurisdiction.

  5. Yes, the respondent committed Grave Misconduct, Dishonesty, and Conduct Prejudicial to the Best Interest of the Service.

  6. Yes, the respondent should be dismissed from service.

PRINCIPLES:

  • The non-payment of prescribed filing fees at the time of filing fails to vest jurisdiction over the case in the trial court.

  • The court acquires jurisdiction over any case only upon the payment of the prescribed docket fee.

  • When insufficient filing fees are initially paid and there is no intention to defraud the government, the court acquires jurisdiction over the case.

  • When there is underpayment of docket fees, the clerk of court or his authorized deputy must make a deficiency assessment and the party filing the action is required to pay the deficiency which shall constitute a lien on the judgment.

  • Lack of jurisdiction may be raised at any stage of the proceedings, but is subject to the doctrine of estoppel by laches.

  • Laches is the failure or neglect, for an unreasonable and unexplained length of time, to assert a right which warrants a presumption that the party entitled to assert it has abandoned or declined to assert it.

  • A party cannot invoke the jurisdiction of a court to obtain affirmative relief against their opponent and later repudiate or question that same jurisdiction.

  • Grave Misconduct is a serious offense involving the transgression of some established and definite rule of action, more particularly, unlawful behavior or gross negligence by a public officer.

  • Dishonesty refers to a disposition to lie, cheat, deceive, or defraud. It is a breach of virtue, a disposition to lie, cheat, deceive, or defraud. It includes any act of omission as contrary to truth as is required by the public, dealing with official functions.

  • Conduct Prejudicial to the Best Interest of the Service refers to any conduct that is a breach of the duty which a public officer or employee owes to the Government, its subordinate officers, the people or to the general public.