15 Mijares V Ranada
15 Mijares V Ranada
15 Mijares V Ranada
Facts:
On 9 May 1991, ten Filipino citizens who suffered human rights abuses in the hands of military forces
during the Marcos regime filed with US district court in Hawaii against Estate of Ferdinand Marcos US
District Court and Affirmed and awarded them $1,964,005,859.90 as compensatory and exemplary
damages. Petitioners then filed a Complaint with Makati RTC for the enforcement of the Final Judgment.
Marcos Estate filed a motion to dismiss, raising the non-payment of the correct filing fees paying only
P410 , notwithstanding the fact that they sought to enforce a monetary amount of damages in the amount
of over Two and a Quarter Billion US Dollars (US$2.25 Billion) citing Supreme Court Circular No. 7,
pertaining to the proper computation and payment of docket fees. In response, the petitioners claimed
that an action for the enforcement of a foreign judgment is not capable of pecuniary estimation; hence, a
filing fee of only Four Hundred Ten Pesos (P410.00) was proper, pursuant to Section 7(c) of Rule 141.
On 9 September 1998 RTC dismissed the subject without prejudice stating that contrary to the petitioners'
submission, the subject matter of the complaint was indeed capable of pecuniary estimation hence
petitioners filed a Petition for Certiorari under Rule 65
Issue:
What provision should govern in filling fees on actions to enforce foreign judgements
Rulling:
Absent perhaps a statutory grant of jurisdiction to a quasi-judicial body, the claim for
enforcement of judgment must be brought before the regular courts, we find that this case is covered by
Section 7(b)(3) of Rule 141, involving as it does, "other actions not involving property. As crafted, Rule
141 of the Rules of Civil Procedure avoids unreasonableness, as it recognizes that the subject matter of an
action for enforcement of a foreign judgment is the foreign judgment itself, and not the right-duty
correlatives that resulted in the foreign judgment. In this particular circumstance, given that the
complaint is lodged against an estate and is based on the US District Court's Final Judgment, this foreign
judgment may, for purposes of classification under the governing procedural rule, be deemed as
subsumed under Section 7(b)(3) of Rule 141., within the class of "all other actions not involving
property." Thus, only the blanket filing fee of minimal amount is required