Spouses Belen Gregorio v. Hon. Zosimo Angeles

Summary

The Supreme Court reversed a trial court's dismissal of a collection suit where petitioners failed to specify the amount of exemplary damages sought. The Court distinguished this case from Manchester Development Corporation, ruling that failure to specify exemplary damages is not fatal when the complaint contains sufficient specified sums for actual damages to enable computation of docket fees. The Court emphasized that exemplary damages are discretionary under the Civil Code and cannot be recovered as a matter of right, with their amount determinable during trial. Since this was essentially a specific performance case for a loan contract with clearly specified actual damages (principal, interest, attorney's fees), the unspecified exemplary damages did not warrant dismissal. The Manchester doctrine should only apply where there is a clear attempt to defraud the government through fee evasion.