Manchester Development v. CA - Case Digest
Manchester Development v. CA - Case Digest
GANCAYCO, J.:
FACTS: Manchester Development Corporation filed a complaint for specific performance and
damages against City Land Development Corporation. Manchester asks the Court to order
defendants to execute a contract of purchase and sale of the subject property and to annul City
Land’s illegal forfeiture of Manchester’s money in the sum of P3 Million pesos paid by Manchester
for the subject property. Manchester also asks the Court to order City Land to pay actual,
compensatory, and exemplary damages. The amount of damages sought is not specified in the
prayer although the body of the complaint alleges the total amount of over P78 Million as damages
suffered by plaintiff.
Upon the filing of the complaint, the amount of P410 was paid as docket fee based on the ground
that the action is merely one for specific performance where the amount involved is not capable of
pecuniary estimation. The total amount of damages sought is not stated in the prayer of the
complaint but it is spelled out in the body of the complaint totalling in the amount of P78, 750, 000.
The underassessment was brought to the attention of the Court together with other similar other
cases and the Court immediately ordered an investigation. Meanwhile, the plaintiff, through
another counsel with leave of court, filed an Amended Complaint wherein the mention the amount
of damages in the body of the complaint was eliminated while maintaining the original prayer.
The Court issued an order to reassess the docket fee in the present cases and all other cases
investigated. The Trial Court directed the plaintiffs to rectify the Amended Complaint by stating the
amounts which they are asking for. The plaintiffs specified the amount of damages in the body of
the complaint in the reduced amount of P10, 000, 000. Still, no amount of damages was specified in
the prayer. The Amended Complaint was admitted.
Petitioner Manchester in support of their contention that the filing fee must be assessed on the
basis of the amended complaint cites the case of Magaspi v. Ramolete. They contend that the Court
of Appeals erred in ruling that the filing fee should be levied by considering the amount of damages
sought in the original complaint.
ISSUE: Whether the filing fee should be based on the amount stated in the Amended Complaint
instead of the Original Complaint
HELD: The facts of the case in Magaspi v. Ramolete is different from the present case.
There was an honest difference of opinion as to the nature of the action in the Magaspi case. The
Magaspi case was an action for recovery of ownership and possession of a parcel of land with
damages, while the present case is an action for torts and damages and specific performance with
prayer for temporary restraining order, etc.
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 docketing fee should be assessed by considering the amount of damages as
alleged in the original complaint.
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 all 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 of Appeals therefore, aptly ruled in the present case that the basis of assessment of the
docket fee should be the amount of damages sought in the original complaint and not in the
amended complaint.
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 in so far as it is inconsistent with this pronouncement is
overturned and reversed.