MIJARES

v RTC Judge RANADA and Estate of Ferdinand Marcos thru its legal
representative appointed by District Court of Hawaii, Imelda Marcos and
Ferdinand Marcos Jr.
FACTS:

1. Petitioners were the victim of human rights violating during the Martial Law.
Unable to confront the Marcos himself, they brought an action against his
Estate wherein they acquired judgment in their favor. In order that they
enforce the judgment awarded to them by a foreign court, the RTC required
the petitioners to pay 472M.
2. Essential facts:
o Petitioners brought a complaint in the US District Court of Hawaii
against the Estate of Marcos.
- The Alien Tort act was invoked as basis for USDCs
jurisdiction over the complaint as it involved a suit by
aliens for tortious violations of international law.
o Final Judgment was ordered and awarded the plaintiff class a total of
almost $2B. This decision was affirmed by the US CA.
3. Petitioners filed a complaint with the RTC of Makati for the enforcement of
the Final Judgment.
4. Marcos Estate filed a Motion to Dismiss on the ground of non-payment of the
correct filing fees. Petitioners opposed the Motion to Dismiss on the ground
that the enforcement of foreign judgment is not capable of pecuniary
estimation.
5. RTC Judge Ranada dismissed the complaint.
o The subject matter of the complaint was capable of pecuniary
estimation as it involved a judgment rendered by a foreign court
ordering the payment of definite sums of money, allowing for easy
estimation.
o The filing fee that the petitioner should pay is P472M
o A MFR was filed but was denied.
6. Hence this petition.
o Petitioners submit that their action is incapable of pecuniary
estimation as the subject matter of the suit is the enforcement of
foreign judgment and not an action for the collection of sum of money
or recovery of damages. Also, if ordered to pay P472M, this would be
violative of the rule that there should be an inexpensive disposition of
every action.
o CHR intervened in the case. It urged that petition be granted and a
judgment rendered for the execution of judgment. RTC erred in
interpreting the action for the execution of a foreign judgment as a
new case. This is in violation of the principle that once a case has been
decided between the same parties in one country on the same issue
with finality, it could no longer be reiterated in another country.

ISSUE: W/N the judgment of foreign court should be enforced
HELD: YES.
1. The respondent Judge erroneously interpreted that the Rules on
Computation of Filing Fee. Section 7(a) , Rule 141 covers money claims
against estates which are not based on judgment. While the petitioners
complaint has been lodged against an estate, it is clearly based on a
judgment, particularly the Final Judgment of the USDC. Thus, this rule has no
application in the petitioners complaint.
2. On the other hand, the petitioners relied on Section 7(b) of Rule 141 covers
actions where the value of the subject matter cannot be estimated. While this
rule provides that the assessed value of the property shall be the basis in
computing the filing fee, it is not applicable in the case at bar. A real action is
one where the plaintiff seeks recovery affecting title of real property. In the
case at bar, the complaint or award for damages adjudicated by the USDC
does not involve any real property of the Marcos Estate.
3. SO, WHAT SHOULD BE THE BASIS OF DDETERMINING FILING FEES FOR
AN ACTION TO ENFORCE A FOREIGN JUDGMENT?
a. There is an evident distinction between a foreign judgment in an action in
rem and one in personam.
o For action in rem- the foreign judgment is deemed conclusive
upon the title to the thing.
o For action in personam- foreign judgment is presumptive and not
conclusive of a right as between the parties and their successors in
interest by subsequent title.
In both cases, the foreign judgment is susceptible of impeachment
on the grounds of want of jurisdiction, collusion, fraud, or mistake
of law or fact.
b. There is a distinction between the cause of action arising from the
enforcement of a foreign judgment and that arising from the facts or
allegations that occasioned the foreign judgment.
o Example:
-A complaint for damages against tortfeasor, the cause of action
arises from the act of the tortfeasor.
*The proof should establish the tortious act itself.
- On the other hand, for the enforcement of judgment awarding
damages from the same tortfeasor, the cause of action derives
from the foreign judgment itself.
*The proof is the judgment itself. No need to prove the facts.
-This is the policy of preclusion. It seeks to protect a
party expectations resulting from previous litigation to
put a rest and quietness to the litigation
c. So is the judgment of the foreign court capable of pecuniary estimation:
THE SC RULED IN THE AFFIRMATIVE
o While the action is enforcement of judgment, the effect of a
providential award would be the adjudication of as sum of money.
o It is ruled by Section 7(3)(b) of the Rule 141. Other actions not
involving property. Thus, petitioner correctly paid the filing fees
 for the amount paid by them is the same when the action is not
capable of pecuniary estimation.
2. Besides the procedural shits of the enforcement of foreign judgment the SC
discussed the theory behind the enforcement of foreign judgments;
a. POLICY OF PRECLUSION
b. Principles of comity, utility and convenience of nations.
-While there is still no treaty enacted guidelining the rules on how the
enforcement of foreign judgment should be done or universal treaty
rendering it obligatory force, the viability of such recognition and
enforcement is essential.
-Whatever be the theory as to the basis for recognizing foreign
judgments, there can be little dispute that the end is to protect the
reasonable expectations and demands of the parties. Where the parties have
submitted a matter for adjudication in the court of one state, and proceedings
there are not tainted with irregularity, they may fairly be expected to submit,
within the state or elsewhere, to the enforcement of the judgment issued by
the court.
-Public policy as a defense to the recognition of judgment has been
recognized in this jurisdiction.
This defense allows for the application of local standards in reviewing
the foreign judgment, especially when such judgment creates only a
presumptive right, as it does in cases wherein the judgment is against
a person. The public policy defense can safeguard against possible
abuses to the easy resort to offshore litigation if it can be
demonstrated that the original claim is noxious to our constitutional
values.