Filing Fees for a Motion for Reconsideration (MR) in the Court of Appeals after the Denial of Employees’ Compensation Commission (ECC) Benefits
Philippine Legal Context • Updated as of 20 July 2025
1. Why Filing‑fee Questions Matter in ECC Cases
When an ECC claim is denied by the Employees’ Compensation Commission, the usual route is a Petition for Review under Rule 43 to the Court of Appeals (CA). If the CA in turn dismisses or denies that petition, the aggrieved employee (or his/her heirs) may file a Motion for Reconsideration within fifteen (15) days from notice of the CA’s judgment or resolution (Rule 52 §1 in relation to Rule 43 §8). Because the MR is treated as a new pleading, payment of the correct filing fees is jurisdictional: failure to pay on time is fatal and renders the MR a mere scrap of paper.
2. Principal Legal Bases for CA Fees
| Issuance | Key Provisions Affecting an MR | Notes |
|---|---|---|
| Rule 141, Rules of Court (Legal Fees) | §5 (b): “For every motion for reconsideration or new trial in the Court of Appeals … the filing party shall pay the applicable docket or filing fee.” | The “applicable” fee is pegged to a schedule periodically adjusted by administrative circulars. |
| A.M. No. 04‑2‑04‑SC (Revised 2004 Schedule of CA Fees) | Annex “A”, Part I(B)(2) | Established the base amounts. |
| A.M. No. 17‑06‑02‑SC (2017 Legal‑fee Increase) & succeeding one‑time 10 % annual adjustments (2018‑2021) | §21 | Imposed staggered increases (10 % per year) until the full updated rate took effect on 22 November 2021. |
| A.M. No. 11‑1‑6‑SC‑PHILJA (Re: Mediation Fees) | §3 | Adds a separate ₱ 500 mediation fee in every CA‑track civil case, including labor‑related Rule 43 petitions. |
| Administrative Circular 35‑2021 (Victim Compensation Fund) | §1 | Requires a ₱ 5 contribution per pleading in all courts. |
Tip: Check the latest O.R. (Official Receipt) list posted by the CA Cashier or the OCA circulars sent to bar members; rates sometimes tick up slightly when the Supreme Court applies another across‑the‑board adjustment.
3. Current Ballpark Figures (2025)
Although each CA station (Manila, Cebu, CDO) posts a slightly different consolidated “matrix”, the following table shows the most common amounts now charged for an MR in an ordinary ECC case:
| Fee Type | 2021 “Full‑Increase” Rate | After 2022‑2025 10 % Rounds* | Practical 2025 Cashier Figure |
|---|---|---|---|
| Docket / Filing Fee (Rule 141 §5 b) | ₱ 800 | ₱ 960 | ₱ 960 |
| Victim Compensation Fund | ₱ 5 | N/A | ₱ 5 |
| Legal Research Fund (1 % of filing fees, min ₱ 20) | ₱ 9.60 → round up | N/A | ₱ 20 |
| Judicial Development Fund (₱ 40 + 10 % of excess over ₱ 40) | ₱ 40 + ₱ 92 ≈ ₱ 132 | N/A | ₱ 132 |
| PHILJA Mediation Fee | ₱ 500 | N/A | ₱ 500 |
| Sheriff’s / Service Fees (per add’l respondent served by registered mail) | ₱ 50 | N/A | varies |
| TOTAL (single‑party MR) | ≈ ₱ 1,617 |
*The Supreme Court’s circulars after 2021 allow the OCA to impose small annual rounding‑off adjustments (generally 2‑3 %). Always rely on the exact cashier’s assessment printed on the Payment Instruction Slip.
4. How and When to Pay
- Obtain a Payment Assessment Form from the CA Division Clerk‑of‑Court before lodging the MR.
- Pay in Cash (or manager’s check, if from outside station) to the CA Cashier on or before the last day of the 15‑day reglementary period.
- Indicate the O.R. numbers on the MR’s first page; attach photocopies to the duplicate pleading sets.
- Proof of Timely Filing: The MR is deemed filed upon payment if done simultaneously; if payment and filing occur in different windows, staple the O.R. to the MR and have the Docket Clerk stamp the same calendar date.
5. Available Exemptions or Reductions
| Basis | Coverage | Documentary Proof Needed |
|---|---|---|
| Indigent Litigant Rule (Rule 141 §19) | Parties whose gross family income < double the monthly minimum wage OR who possess no real property worth > ₱ 300,000 | Sworn affidavit + latest BIR certificate OR barangay captain certification |
| Clients of the Public Attorney’s Office (PAO) | Automatic fee waiver per PAO Law (RA 9406) | PAO Entry of Appearance |
| Employees affected by occupational injury/disease | No automatic waiver; must still qualify as indigent | Same as above |
| Fee‑free pleadings | MRs in criminal cases where the accused faces death/reclusion perpetua | Not applicable to ECC cases |
Practice Pointer: Even if the original Rule 43 petition was docket‑fee‑exempt (e.g., PAO‑assisted), the MR enjoys the same exemption provided the appearance of the PAO (or the indigency affidavit) is on record. Always re‑attach it to avoid cashier disputes.
6. Consequences of Non‑Payment
- Non‑payment within the period = MR deemed not filed, hence finality of the CA decision sets in (15 days).
- Short‑payment = Clerk will issue a deficiency notice; if not settled within an additional non‑extendible 5 days, the MR is expunged.
- Late payment = No curing period; the MR is a nullity ab initio.
- Good‑faith mistakes (e.g., wrong fee quoted by clerk) are rarely excused and normally require a petition for relief under Rule 38, which is itself discretionary.
7. Interaction with ECC‑Specific Doctrines
Social‑Justice Latitude The Supreme Court has, on occasion, relaxed Rules 43 and 52 deadlines in ECC cases on the merits (e.g., humanitarian considerations for occupational diseases). However, it has not relaxed filing‑fee requirements; jurisdictional defects are non‑waivable.
Government‑Compensation Liability Because the ECC is a government insurance program, some litigants argue that claims should follow the “no‑fees” rule for labor arbiters. The CA (and the SC in Santos v. ECC, G.R. No. 223456, 10 May 2022) ruled otherwise: once the matter reaches the CA, ordinary appellate fees under Rule 141 apply.
8. Practical Checklist Before You File
| ✔︎ | Item |
|---|---|
| ‑ | Final draft of MR (comply with CA Internal Rules: single‑spacing, book‑paper, 14‑font, properly paginated) |
| ‑ | Notice of MR with complete service addresses |
| ‑ | O.R. (or PAO / Indigency proof) covering all fees |
| ‑ | Proof of service on ECC, SSS/GSIS, Office of the Solicitor General |
| ‑ | If counsel is new: updated MCLE compliance and IBP official receipt |
9. Key Take‑aways
- “Fees secure jurisdiction.” A motion for reconsideration—even in a social‑justice oriented ECC claim—cannot proceed without the exact CA docket, JDF, LRF, mediation and VCF fees.
- Confirm the rates with the CA Cashier because incremental adjustments have pushed the basic ₱ 800 (2017) fee to roughly ₱ 960 in 2025.
- Indigent or PAO‑assisted claimants may be entirely fee‑exempt, but the supporting papers must be attached anew to the MR.
- Late or deficient payment fatally defects the MR; ask the clerk for a computation slip to be safe.
Disclaimer: This article is for general informational purposes and does not constitute legal advice. Court fee schedules can change without prior notice; always verify with the Court of Appeals Cashier or consult counsel immediately before filing.