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HEIRS OF REINOSO V.

CA
Summary: The heirs of Reinoso filed a complaint for damages arising from their fathers
death in a collision between a passenger jeepney and a truck. The RTC ruled in their
favor, but the CA reversed the decision on the ground of non-payment of docket fees.
The SC reversed the CA and reinstated the RTC decision. While the case of Manchester
v. CA. Where the initiatory pleading is not accompanied by the payment of the docket
fee, the court may allow payment of the fee within a reasonable amount of time, but in
no case beyond the applicable reglementary period. However, petitioners are liable for
the difference between the actual fees paid and the correct payable docket fees to be
assessed by the clerk of court which shall constitute a lien on the judgment.
Facts:
Petition for review assailing the decision and the resolution of the CA
The case at bar originated from a complaint for damages arising from the
collision of a passenger jeepney and a truck. As a result of this collision, a
passenger of the jeepney, Ruben Reinoso was killed.
The heirs of Reinoso filed a complaint for damages against Ponciano Tapales
(jeepney owner) and Jose Guballa (truck owner). Guballa filed a 3 rd party
complaint against Filwriters Guaranty Assurance Co. (FGAC).
RTC ruled in favor of petitioners and against Guballa.
On appeal, the CA reversed and set aside the RTC decision. It dismissed the
complaint on the ground of non-payment of docket fees pursuant to Manchester
v. CA (Held: A court acquires jurisdiction over any case only upon the payment of
the prescribed docket fee). Since prescription had set in already, petitioners
could no longer pay the required docket fees.
Petitioners filed an MR before the CA, but this was denied. Hence, this appeal.
Issues and Held:
WoN the CA misapplied the ruling in Manchester v. CA- YES.
o Pets argue:
Manchester should not have been applied retroactively in the case
at bar, since it was filed prior to the promulgation of the
Manchester decision in 1987
At the time of the filing of the complaint in 1979, they were not
certain of the amount of damages they were entitled to, because
the amount of lost income would still be finally determined in the
course of the trial
Jurisdiction of the TC remains even if there was failure to pay the
correct filing fee as long as the correct amount would be paid
subsequently
The alleged defect was never put in issue either in the RTC or in
the CA
o SC: Given the ff. circumstances, there is a need to suspend the strict
application of the rules so that the petitioners would be able to fully and
finally prosecute their claim on the merits rather than fail to secure justice
on a mere technicality:
While the ruling in Manchester was correctly cited by the TC, such
ruling was relaxed 2 years later in Sun Insurance Office v.

Asuncion, wherein the Court decreed that where the initiatory


pleading is not accompanied by the payment of the docket fee, the
court may allow payment of the fee within a reasonable amount of
time, but in no case beyond the applicable prescriptive or
reglementary period.
The issue was never brought up in the proceedings before the TC
It was only the CA which motu proprio dismissed the case
The case was filed before the Manchester ruling came out
Even if said ruling was filed before the Manchester ruling came
out, liberality should be accorded given the recency of the ruling
However, petitioners are liable for the difference between the actual fees
paid and the correct payable docket fees to be assessed by the clerk of
court which shall constitute a lien on the judgment pursuant to Sec. 2,
Rule 141.
Normally, the case should be remanded to the CA, but given the case had
been ongoing for more than 30 years, the SC resolved the case already:
Sustained the RTC finding that the evidence presented by Guballa was
wanting. He failed to rebut the presumption of negligence by showing that
he had exercised the due diligence required of him.

Ruling:
Petition granted; CA reversed, RTC decision reinstated.

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