Manchester Development Corporation vs CA

Topic: Filling Fees

FACTS:
A complaint for specific performance was filed by
Manchester Development Corporation against
City Land Development Corporation to compel
the latter to execute a deed of sale in favor
Manchester. Manchester also alleged that City
Land forfeited the former’s tender of payment for
a certain transaction thereby causing damages to
Manchester amounting to P78,750,000.00. This
amount was alleged in the BODY of their
Complaint but it was not reiterated in the
PRAYER of same complaint. Manchester paid a
docket fee of P410.00 only. Said docket fee is
premised on the allegation of Manchester that
their action is primarily for specific performance
hence it is incapable of pecuniary estimation.
The court ruled that there is an under
assessment of docket fees hence it ordered
Manchester to amend its complaint. Manchester
complied but what it did was to lower the amount
of claim for damages to P10M. Said amount was
however again not stated in the PRAYER.
ISSUE:
Whether or not the amended complaint should be
admitted.
HELD:
No. The docket fee, its computation, should
be based on the original complaint. A case is
deemed filed only upon payment of the
appropriate docket fee regardless of the actual
date of filing in court. Here, since the proper
docket fee was not paid for the original
complaint, it’s as if there is no complaint to speak
of. As a consequence, there is no original
complaint duly filed which can
be amended. So, any subsequent proceeding
taken in consideration of the amended complaint
is void.
Manchester’s defense that this case is primarily
an action for specific performance is not merited.
The Supreme Court ruled that based on the
allegations and the prayer of the complaint, this
case is an action for damages and for specific
performance. Hence, it is capable of pecuniary
estimation.
Further, the amount for damages in the original
complaint was already provided in the body of
the complaint. Its omission in the prayer
clearly constitutes an attempt to evade the
payment of the proper filing fees. To stop the
happenstance of similar irregularities in the
future, the Supreme Court ruled that from this
case on, 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 bib accepted nor
admitted, or shall otherwise be expunged
from the record.