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Heirs of the Late Ruben Reinoso Sr., v. CA (2011) prescribed docket fee.

prescribed docket fee. The strict application of this rule was, however,
relaxed two (2) years after in the case of Sun Insurance Office, Ltd. v.
Doctrine: A reiteration of the more liberal Sun Insurance case. Where Asuncion
the party does not deliberately intend to defraud the court in payment of
docket fees, and manifests its willingness to abide by the rules by paying The Court also takes into account the fact that the case was filed
additional docket fees when required by the court, the liberal doctrine before the Manchester ruling came out. Even if said ruling could be
enunciated in Sun Insurance Office, Ltd., and not the strict regulations applied retroactively, liberality should be accorded to the petitioners in
set in Manchester, will apply. view of the recency then of the ruling. Leniency because of recency was
applied to the cases of Far Eastern Shipping Company v. Court of
Facts: Appeals. RTC decision was reinstated

In 1979, Ruben Reinoso was a passenger in a jeepney


traversing E. Rodriguez Ave. The jeepney owned by Tapales, collided
with a truck owned by Guballa. Reinoso died as a result of the collision.
His heirs filed the instant case for Damages against Tapales and Guballa

IN 1988, RTC found the Truck liable and held Guballa liable for
damages sustained by the Heirs of Reinoso and the jeepney owner.
Case litigated before the RTC which rendered a decision In 1994, CA
motu propio dismissed the petition on the ground of nonpayment of
docket fees pursuant to the 1987 Manchester ruling

Reinoso’s defense: Manchester should not be made to apply


retroactively to their case as the case was filed prior to the promulgation
of Manchester ruling

ISSUE:

The dismissal by the CA was proper due to the nonpayment of


docket fees?

HELD:

No. The Court reiterates the ruling in Sun Insurance v. Asuncion, the
case at bench has been pending for more than 30 years and the records
thereof are already before this Court, a remand of the case to the Court
of Appeals (CA) would only unnecessarily prolong its resolution.

In Manchester v. Court of Appeals, it was held that a court


acquires jurisdiction over any case only upon the payment of the

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