**Metropolitan Bank and Trust Co. and Solidbank Corporation vs. Bernardita H. Perez: A Case of Lease Contract Termination and Unrealized Income**
### Facts:
Solidbank Corporation entered into a 15-year lease contract with Bernardita H. Perez for two parcels of land in Sta. Maria, Bulacan, starting January 1, 1998. A bank-specific structure was erected on the premises. Subsequently, Solidbank was acquired by Metropolitan Bank and Trust Company (Metrobank). On September 24, 2002, Metrobank issued a notice of lease termination effective September 30, 2002.
Challenging this pre-termination, Perez filed a complaint against Solidbank and Metrobank for breach of contract and damages in the Regional Trial Court (RTC) of Malolos, Bulacan, seeking unrealized income from the lease’s early cessation. Metrobank contended that the lease allowed for pre-termination. After several unexcused absences, Metrobank was deemed to have waived its right to present evidence. The Malolos RTC sided with Perez, ordering the petitioners to pay for unrealized income and damages.
Metrobank appealed, arguing the trial court lacked jurisdiction due to insufficient docket fees paid by Perez. The Court of Appeals affirmed the RTC’s decision. Metrobank then escalated the matter to the Supreme Court, invoking the Manchester rule on docket fees and pleading admission.
### Issues:
1. Whether the trial court acquired jurisdiction over the case despite Perez’s insufficient payment of docket fees.
2. The applicability of Manchester Development Corporation v. Court of Appeals and Sun Insurance Office, Ltd. v. Asuncion doctrines.
3. The award of unrealized income, moral and exemplary damages, and attorney’s fees.
### Court’s Decision:
The Supreme Court partly granted the petition. It revisited and modified the Court of Appeals decision, emphasizing that jurisdictional fees could be reassessed and collected within appropriate periods. While highlighting exceptions in cases where damages could not be precisely determined at the complaint filing time, it ruled that Perez should pay the difference in docket fees based on the computed unrealized income, as it constitutes a lien on the judgment.
The Court differentiated between the discretion allowed in assessing fees for indeterminate claims and the mandate to specify claim amounts post-judgment. It found Metrobank’s stance on the alleged deliberate concealment of underpaid fees by Perez unsubstantiated, given the future income’s speculative nature upon complaint filing.
The award of moral and exemplary damages and attorney’s fees was voided due to the lack of categorical evidence demonstrating Perez experienced emotional distress warranting such awards.
### Doctrine:
The decision reiterated the relaxed stance on the Manchester rule from Sun Insurance Office, highlighting jurisdictional fees’ payment flexibility within prescriptive periods and underlining the definitive requirement for factual bases in obtaining damages and attorney’s fees.
### Class Notes:
1. **Jurisdiction & Docket Fees**: Jurisdictional requirement met when docket fees are paid within the reglementary period, even if initially insufficient, provided there’s no intent to defraud.
2. **Manchester Rule**: Requires specificity in the claims amount; however, flexibility permitted if the damages become quantifiable within the legal period.
3. **Damages & Attorney’s Fees**: Awards require categorical evidence of emotional distress and clear demonstration of agreement or incurred expenses.
### Historical Background:
This case mirrors evolving jurisprudence on procedural requirements (docket fees, specificity of claims) balancing between strict rule adherence and practical challenges in litigation, especially in determining speculative future damages. It underscores the judiciary’s role in ensuring fair processes while preventing the exploitation of procedural lapses to evade jurisdictional responsibilities.
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