(Mijares v. Ranada) (Agapito) C2021

Mijares v.
Ranada
GR 139325 | April 12, 2005
TINGA J.
Doctrine: SC opined that there is temptation in employing short-cuts to arrive at what might seem
the desirable solution but easy, reflexive resort to the equity principle all too often leads to a result
that may be morally correct, but legally wrong.
FACTS
[Petition for Certiorari]
Invoking the Alien Tort Act, petitioners Mijares, et al., which are all human rights victims
during the Marcos era, obtained a Final Judgment in their favor against the Estate of the late
President Marcos amounting to roughly 1.9 Billion U.S. Dollars in damages for tortuous violations
of international law in the US District Court of Hawaii. This Final Judgment was affirmed by the
US Court of Appeals.
After which, petitioners filed a Complaint with the RTC of Makati for the enforcement
of the Final Judgment, paying Php 410.00 as docket and filing fees based on Rule 141, Section
7(b) where the value of the subject matter is incapable of pecuniary estimation. Marcos Estate filed
a motion to dismiss, raising, among others, the non-payment of the correct filing fees. Respondent
Judge Ranada of the RTC Makati issued the subject Order dismissing the complaint without
prejudice.
Respondent judge opined that contrary to the petitioners’ submission, the subject matter of
the complaint was indeed 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 determination
of the value of the foreign judgment. Petitioners filed a Motion for Reconsideration, which Judge
Ranada denied in an Order. Hence, this petition.
ISSUES AND HOLDING
1. W/N the amount paid by the Petitioners is the proper filing fee? [No]
No. but on a different reason. Petitioners argued that the complaint incapable of pecuniary
estimation as the subject matter of the suit is the enforcement of a foreign judgment, and not an
action for the collection of a sum of money or recovery of damages. They also point out that to
require the class plaintiffs to pay P472,000,000.0 in filing fees would negate and render inutile the
liberal construction ordained by the Rules of Court, as required by Section 6, Rule 1 of the Rules
of Civil Procedure, particularly the inexpensive disposition of every action.
On the other hand, Respondent judge opined that 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 determination of the value of the foreign judgment. On that
[AGAPITO] C2021 | 1
score, Section 7(a) of Rule 141 of the Rules of Civil Procedure would apply and the RTC estimated
the proper amount of filing fees P472,000,000.0 which obviously had not been paid.
The SC rule in favor of the petitioners.
The SC opined that the petitioner’s complaint was lodged against the Estate of Marcos but
it is clearly based on a judgment — the Final Judgment of the US District Court. However, the
Petitioners erred in stating that the Final Judgment is incapable of pecuniary estimation because it
is so capable. On this point, Petitioners state that this might lead to an instance wherein a first level
court (MTC, MeTC, etc.) would have jurisdiction to enforce a foreign judgment. Under Batasang
Pambansa 129, such courts are not vested with such jurisdiction.
Section 33 of Batasang Pambansa 129 refers to instances wherein the cause of action or
subject matter pertains to an assertion of rights over property or a sum of money. But here, the
subject matter is the foreign judgment itself. Section 16 of Batasang Pambansa 129 reveals that
the complaint for enforcement of judgment even if capable of pecuniary estimation would fall
under the jurisdiction of the Regional Trial Courts. Thus, the Complaint to enforce the US District
Court judgment is one capable of pecuniary estimations but at the same time, it is also an action
based on judgment against an estate, thus placing it beyond the ambit of Section 7(a) of Rule 141.
What governs the proper computation of the filing fees over Complaints for the enforcement
of foreign judgments is Section7(b)(3), involving “other actions not involving property.”
[WHEREFORE, the petition is GRANTED. The assailed orders are NULLIFIED and SET
ASIDE, and a new order REINSTATING Civil Case No. 97-1052 is hereby issued.]
[AGAPITO] C2021 | 2

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Mijares v.

[Petition for Certiorari]

ISSUES AND HOLDING

The SC rule in favor of the petitioners.

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