### Facts:
The case began when Isabel G. Ramones (petitioner) filed a criminal case against Spouses Teodorico Jr. and Elenita Guimoc (respondents) for Other Forms of Swindling under Article 316 (2) of the RPC. The case was initially filed on June 30, 2006, before the Municipal Trial Court (MTC) of Mariveles, Bataan. The complaint accused the respondents of fraudulently obtaining a loan of P663,000.00 from Ramones with a promise to sell their house and lot, despite knowing the property was already mortgaged.
After payment of P500.00 as docket fees by the petitioner, the trial proceeded at the MTC. The court acquitted Teodorico but found Elenita guilty, imposing a sentence and ordering civil liabilities for both respondents. Unhappy with the decision, respondents appealed to the Regional Trial Court (RTC), arguing the MTC lacked jurisdiction due to improper docket fee payment. The RTC modified the MTC’s decision, maintaining the civil liabilities. This was further appealed to the Court of Appeals (CA), which initially affirmed the RTC’s decision but later amended it to delete the award of damages based on the respondents’ motion regarding the incorrect docket fee issue. The case was finally moved to the Supreme Court under a petition for review filed by the petitioner.
### Issues:
1. Whether or not the MTC acquired jurisdiction over the case despite the alleged incorrect payment of docket fees.
2. Whether the CA correctly deleted the award of damages due to the improper payment of docket fees.
### Court’s Decision:
The Supreme Court ruled in favor of the petitioner, holding that the court a quo properly acquired jurisdiction over the case despite the alleged underpayment of docket fees. The Court pointed out the established principle that jurisdiction is acquired upon the full payment of the docket fees as assessed by the clerk of court, regardless of whether the initial payment was deficient, provided there was no intent to defraud the government.
It emphasized that the petitioner’s payment of P500.00 as assessed, along with her willingness to pay additional fees, dispelled any bad faith. Furthermore, the Court addressed the delay of respondents in raising the docket fee issue, noting that failure to timely question jurisdiction may bar the party from doing so later due to estoppel by laches.
### Doctrine:
1. **Jurisdiction Over Case:** A court acquires jurisdiction over any case only upon the payment of the prescribed docket fee, and an underpayment, if assessed and sanctioned by the clerk of court without intent to defraud the government, does not impede jurisdiction.
2. **Estoppel by Laches:** A party may be barred from questioning the jurisdiction of a court if the issue was not timely raised and the party has otherwise invoked the court’s jurisdiction to secure affirmative relief.
### Class Notes:
– **Jurisdiction and Docket Fees:** The jurisdiction of a court is contingent upon the payment of prescribed docket fees. A deficiency in docket fees, when assessed and collected after initial proceedings, does not nullify the court’s jurisdiction.
– **Estoppel by Laches in Jurisdictional Challenges:** Parties must raise jurisdictional challenges at the earliest opportunity. Delaying such a challenge, especially after seeking relief under the court’s jurisdiction, may result in the party being barred from questioning jurisdiction later on.
### Historical Background:
This case reflects the evolving interpretation of rules regarding the payment of docket fees and jurisdiction. It underscores the balance between strict adherence to procedural requirements and judicial leniency in ensuring fair access to justice, especially when parties act in good faith. The decision reiterates the importance of timely objection to jurisdictional issues and elucidates the principle that jurisdictional challenges can be overcome by estoppel by laches.
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