Yuchengco v. Republic

G.R. No. 131127 (June 8, 2000)

SC ruled Alfonso T. Yuchengco's late docket fee payment did not dismiss his complaint-in-intervention.

Facts:

On July 16, 1987, the Republic of the Philippines filed a complaint for rescission, reconveyance, restitution, accounting, and damages against Ferdinand E. Marcos, Imelda Marcos, and Prime Holdings, Inc. (PHI) in the Sandiganbayan, which was docketed as Civil Case No. 0002. Alfonso T. Yuchengco, claiming ownership of certain properties sought to be forfeited, filed a motion for intervention and a complaint-in-intervention on August 11, 1988, naming the Republic, the Presidential Commission on Good Government (PCGG), Ferdinand E. Marcos, Imelda Marcos, and PHI as defendants. Yuchengco paid a docket fee of P400.00.

The Sandiganbayan granted the motion for intervention on February 17, 1989, and the Republic filed a motion for reconsideration, which was denied. Subsequently, PHI and the Cojuangcos (the estate of Ramon U. Cojuangco and Imelda O. Cojuangco) filed a motion to dismiss the amended complaint-in-intervention on August 25, 1993, arguing that Yuchengco failed to pay the correct docket fees and that the complaint did not state a cause of action.

Yuchengco filed a second amended complaint-in-intervention on September 6, 1993, and opposed the motion to dismiss. The respondents contended that the amended complaint was essentially an action for the recovery of ownership and possession of shares in the Philippine Telecommunications Investment Corporation (PTIC), and thus, the docket fees should be based on the total value of the shares.

Yuchengco argued that no docket fees were payable to the Sandiganbayan under Section 11 of Presidential Decree No. 1606, which stated that all proceedings in the Sandiganbayan were free of charge. The respondents countered that the Sandiganbayan's jurisdiction had expanded to include civil cases, necessitating the payment of docket fees.

The Sandiganbayan issued several resolutions regarding the motions to dismiss and the payment of docket fees, ultimately ordering Yuchengco to pay a balance of P14,425.00, which he did with reservation. The Sandiganbayan later dismissed Yuchengco's complaint for non-payment of the correct docket fees, leading to this petition for review.

Legal Issues:

The primary legal issue was whether the Sandiganbayan could dismiss Yuchengco's complaint-in-intervention due to the alleged failure to pay the correct amount of docket fees on time. This raised questions about the jurisdictional nature of docket fees, the applicability of the provisions of Presidential Decree No. 1606, and the implications of the Sandiganbayan's previous rulings.

Arguments:

  • Petitioner (Yuchengco):

    • Argued that the Sandiganbayan had previously admitted his complaint-in-intervention and that he had acted in good faith regarding the payment of docket fees.
    • Contended that the proceedings in the Sandiganbayan were free of charge under Section 11 of P.D. 1606, and that subsequent laws did not amend this provision.
    • Asserted that the Sandiganbayan's dismissal of his complaint was unjust, especially given the court's prior admissions and the lack of evidence of any intent to evade payment.

  • Respondents (PHI and the Cojuangcos):

    • Argued that the Sandiganbayan's jurisdiction required the payment of the correct docket fees, and that Yuchengco's failure to specify the value of his claims violated the rules.
    • Contended that the Sandiganbayan's previous rulings did not preclude the requirement for correct docket fees, and that the court had the authority to dismiss the case for non-compliance.

Court's Decision and Legal Reasoning:

The Supreme Court partially granted Yuchengco's petition, setting aside the Sandiganbayan's resolutions that dismissed his complaint. The Court held that while the timely payment of correct docket fees is generally jurisdictional, the circumstances of this case warranted a more equitable approach.

The Court noted that Yuchengco had acted in good faith, seeking clarification on the correct fees and paying the amounts assessed by the Sandiganbayan. The Court emphasized that the Sandiganbayan's earlier admissions of Yuchengco's complaints led him to reasonably believe that his claims were validly filed.

The Court also recognized that the Sandiganbayan's failure to resolve the docket fee issue in a timely manner constituted a supervening event that tolled the prescriptive period for Yuchengco's claims. The Court concluded that the Sandiganbayan should allow Yuchengco to submit the value of the properties he sought to recover and pay the appropriate docket fees within a specified period.

Significant Legal Principles Established:

  1. Jurisdictional Nature of Docket Fees: The timely payment of correct docket fees is generally a jurisdictional requirement for the court to take cognizance of a case.
  2. Equitable Considerations: Courts may consider equitable factors when determining the consequences of non-payment of docket fees, especially when a party has acted in good faith and relied on prior court admissions.
  3. Supervening Events and Prescription: Delays or inaction by the court on critical issues can toll the running of the prescriptive period for claims, preventing the dismissal of cases based on procedural technicalities.