Case Citation: Manchester Devt Corp, et. al. vs.

CA
Petitioners: Manchester Devt Corp, et. al.
Respondents: Court of Appeals, City Land Development Corporation, Stephen Roxas, Andrew
Luison, Grace Luison and Jose De Maisip
Syllabus Topic: Payment of Docket Fees
Doctrine: The Court acquires jurisdiction over any case only upon the payment of the
prescribed docket fee.
Case Summary
Petitioners in this case filed an action for damages and specific performance but did not indicate the amount of
damages prayed for., thus petitioners paid an insufficient filing fee. The Supreme Court Ruled that the trial court
did not acquire jurisdiction yet and reminded that a case is deemed filed only upon payment of the docket fee
regardless of the actual date of filing in court.
Facts ● The Court in this case was acting on the motion for reconsideration filed by
petitioners on the resolution promulgated by Second Division praying to refer the
case to the Court en banc
● Petitioners contend that the Court of Appeals erred in that the filing fee should be
levied considering the amount of damages sought in the original complaint.
● Petitioners in support of their contention that the filing fee must be assessed on
the basis of the amended complaint cite the case of Magaspi vs. Ramolete but the
Court ruled that the facts Magaspi vs Ramolete differ from the facts in the
present case
● In the Magaspi case, the action was considered not only one for recovery of
ownership but also for damages, so that the filing fee for the damages should be
the basis of assessment. Although the payment of the docketing fee of P60.00
was found to be insufficient, nevertheless, it was held that since the payment was
the result of an "honest difference of opinion as to the correct amount to be paid
as docket fee" the court "had acquired jurisdiction over the case and the
proceedings thereafter had were proper and regular.
● In the present case no such honest difference of opinion was possible as the
allegations of the complaint, the designation and the prayer show clearly that it is
an action for damages and specific performance. The docket fee should be
assessed by considering the amount of damages as alleged in the original
complaint; however the plaintiffs did not specify the amount of damages they
were praying for.
Issue: Whether the trial court has acquired jurisdiction over the case. (NO)
SC Ruling: As reiterated in the Magaspi case the rule is well-settled "that a case is deemed filed
only upon payment of the docket fee regardless of the actual date of filing in court.
Thus, in the present case the trial court did not acquire jurisdiction over the case by
the payment of only P410.00 as docket fee.

Neither can the amendment of the complaint thereby vest jurisdiction upon the Court.
For any legal purposes there is no such original complaint that was duly filed which
could be amended. Consequently, the order admitting the amended complaint and all
subsequent proceedings and actions taken by the trial court are null and void.

The Court cannot close this case without making the observation that it frowns at the
practice of counsel who filed the original complaint in this case of omitting any
 specification of the amount of damages in the prayer although the amount of over
P78 million is alleged in the body of the complaint. This is clearly intended for no
other purpose than to evade the payment of the correct filing fees if not to mislead
the docket clerk in the assessment of the filing fee. This fraudulent practice was
compounded when, even as this Court had taken cognizance of the anomaly and
ordered an investigation, petitioner through another counsel filed an amended
complaint, deleting all mention of the amount of damages being asked for in the
body of the complaint. It was only when in obedience to the order of this Court, the
trial court directed that the amount of damages be specified in the amended
complaint, that petitioners' counsel wrote the damages sought in the much reduced
amount of P10,000,000.00 in the body of the complaint but not in the prayer thereof.
The design to avoid payment of the required docket fee is obvious.

To put a stop to this irregularity, henceforth all complaints, petitions, answers and
other similar pleadings should specify the amount of damages being prayed for not
only in the body of the pleading but also in the prayer, and said damages shall be
considered in the assessment of the filing fees in any case. Any pleading that fails to
comply with this requirement shall not be accepted nor admitted, or shall otherwise
be expunged from the record.

The Court acquires jurisdiction over any case only upon the payment of the
prescribed docket fee. An amendment of the complaint or similar pleading will not
thereby vest jurisdiction in the Court, much less the payment of the docket fee based
on the amounts sought in the amended pleading. The ruling in the Magaspi case
insofar as it is inconsistent with this pronouncement is overturned and reversed.
Dispositive Portion
Other/Notes: