Mijares v.

Ranada
Facts:
Invoking the Alien Tort Act, petitioners Mijares, et al.*, all of whom suffered
human rights violations during the Marcos era, obtained a Final Judgment in
their favor against the Estate of the late Ferdinand Marcos amounting to
roughly $1.9B in compensatory and exemplary 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.
As a consequence, Petitioners filed a Complaint with the RTC Makati for the
enforcement of the Final Judgment, paying P410 as docket and filing fees
based on Rule 141, 7(b) where the value of the subject matter is incapable
of pecuniary estimation. The Estate of Marcos however, filed a MTD alleging
the non-payment of the correct filing fees. RTC Makati dismissed the
Complaint stating that the subject matter was capable of pecuniary
estimation as it involved a judgment rendered by a foreign court ordering the
payment of a definite sum of money allowing for the easy determination of
the value of the foreign judgment. As such, the proper filing fee was P472M,
which Petitioners had not paid.
Issue: Whether or not the amount paid by the Petitioners is the proper filing
fee.
Held:
Yes, but on a different basisamount merely corresponds to the same
amount required for other actions not involving property. RTC Makati erred
in concluding that the filing fee should be computed on the basis of the total
sum claimed or the stated value of the property in litigation. The Petitioners
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 err 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 the B.P.129, such
courts are not vested with such jurisdiction. 33 of B.P.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. 16 of B.P.129 reveals that the complaint for
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enforcement of judgment even if capable of pecuniary estimation would fall
under the jurisdiction of the RTCs. 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 7(a) of Rule 141. What governs the proper
computation of the filing fees over Complaints for the enforcement of foreign
judgments is 7(b)(3), involving other actions not involving property.