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Crim Pro Case Digest: Mijares v. Ranada (2005)

G.R. No. 139325             April 12, 2005

Lessons Applicable: In all civil actions in which the subject of the litigation is incapable of pecuniary estimation

Laws Applicable:

  • May 9 1991: a complaint was filed by ten Filipino citizens representing a class of 10,000 members who each alleged having suffered human rights abuses such as arbitrary detention, torture and rape in the hands of police or military forces during the Marcos regime with the United States District Court (US District Court), District of Hawaii, against the Estate of former Philippine President Ferdinand E. Marcos (Marcos Estate)
  • US District Court and Affirmed by US CA: awarded them $1,964,005,859.90
  • Petitioners filed Complaint with Makati RTC for the enforcement of the Final Judgment
  • Marcos Estate filed a motion to dismiss, raising, among others, the non-payment of the correct filing fees paying only P410
  • Petitioners claimed that an action for the enforcement of a foreign judgment is not capable of pecuniary estimation
  •  RTC: estimated the proper amount of filing fees was approximately P472 and dismissing the case without prejudice
  •  Petition for Certiorari under Rule 65
ISSUE: W/N the enforcement of a foreign judgment is incapable of pecuniary estimation

HELD: NO. (But belongs to "other actions not involving property") petition is GRANTED.
  • There is an evident distinction between a foreign judgment in an action in rem and one in personam. For an action in rem, the foreign judgment is deemed conclusive upon the title to the thing, while in an action in personam, the foreign judgment is presumptive, and not conclusive, of a right as between the parties and their successors in interest by a subsequent title
  • However, in both cases, the foreign judgment is susceptible to impeachment in our local courts on the grounds of want of jurisdiction or notice to the party, collusion, fraud, or clear mistake of law or fact. Thus, the party aggrieved by the foreign judgment is entitled to defend against the enforcement of such decision in the local forum. It is essential that there should be an opportunity to challenge the foreign judgment, in order for the court in this jurisdiction to properly determine its efficacy even if such judgment has conclusive effect as in the case of in rem actions, if only for the purpose of allowing the losing party an opportunity to challenge the foreign judgment. Consequently, the party attacking a foreign judgment has the burden of overcoming the presumption of its validity.  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.
  • There are distinctions, nuanced but discernible, 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.  They may pertain to the same set of facts, but there is an essential difference in the right-duty correlatives that are sought to be vindicated. Extensive litigation is thus conducted on the facts, and from there the right to and amount of damages are assessed. On the other hand, in an action to enforce a foreign judgment, the matter left for proof is the foreign judgment itself, and not the facts from which it prescinds.
  • As stated in Section 48, Rule 39, the actionable issues are generally restricted to a review of jurisdiction of the foreign court, the service of personal notice, collusion, fraud, or mistake of fact or law.  The limitations on review is in consonance with a strong and pervasive policy in all legal systems to limit repetitive litigation on claims and issues. Otherwise known as the policy of preclusion, it seeks to protect party expectations resulting from previous litigation, to safeguard against the harassment of defendants, to insure that the task of courts not be increased by never-ending litigation of the same disputes, and in a larger sense to promote what Lord Coke in the Ferrer's Case of 1599 stated to be the goal of all law: "rest and quietness." If every judgment of a foreign court were reviewable on the merits, the plaintiff would be forced back on his/her original cause of action, rendering immaterial the previously concluded litigation.
  • Marcos Estate cites Singsong v. Isabela Sawmill and Raymundo v. Court of Appeals:
    • In determining whether an action is one the subject matter of which is not capable of pecuniary estimation this Court has adopted the criterion of first ascertaining the nature of the principal action or remedy sought.  If it is primarily for the recovery of a sum of money, the claim is considered capable of pecuniary estimation, and whether jurisdiction is in the municipal courts or in the courts of first instance would depend on the amount of the claim.  However, where the basic issue is something other than the right to recover a sum of money, where the money claim is purely incidental to, or a consequence of, the principal relief sought, this Court has considered such actions as cases where the subject of the litigation may not be estimated in terms of money, and are cognizable exclusively by courts of first instance (now Regional Trial Courts).
  • An examination of Section 19(6), B.P. 129 reveals that the instant complaint for enforcement of a foreign judgment, even if capable of pecuniary estimation, would fall under the jurisdiction of the Regional Trial Courts
  • The complaint to enforce the US District Court judgment is one capable of pecuniary estimation. 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. It is covered by Section 7(b)(3), involving as it does, "other actions not involving property."  The petitioners thus paid the correct amount of filing fees, and it was a grave abuse of discretion for respondent judge to have applied instead a clearly inapplicable rule and dismissed the complaint.