G.R. No. L-32392 - Aguilar vs. Blanco

Title: Aguilar vs. Blanco

Case: G.R. No. L-32392

Decision Date: Aug 13, 1988

A dispute over land possession led to a delayed appeal due to postal inefficiency; the Supreme Court ruled the appeal untimely, reinstating the final judgment.

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Case Digest (G.R. No. L-32392)
Legal Reasoning Model

Facts:

Original Judgment and Case Background

On June 26, 1963, in Civil Case No. 7 entitled "Aurea Aguilar and Leopoldo Arias vs. Leopoldo Labyang and Juanito Daquipal," the Municipal Court of San Enrique rendered a judgment:

Defendant Leopoldo Labyang was enjoined from committing acts of dispossession against the plaintiffs, who were spouses.

Labyang was ordered to pay P400 as actual damages, P200 as attorney’s fees, plus the costs of the action.

The action against Juanito Daquipal was dismissed.

The judgment, rendered by the Municipal Court, later became the focal point of multiple appeals and motions.

Notice of Appeal and Filing of Bond

On July 23, 1963, Defendant Labyang filed a notice of appeal with the Municipal Court of San Enrique and secured an appeal bond, later transmitting the case records to the Court of First Instance of Iloilo where the appeal was docketed as Civil Case No. 6359.

There was a dispute regarding the actual date the Municipal Court’s decision was received by Labyang’s counsel (claims of July 2 versus July 15, 1963).

Motion to Dismiss the Appeal in the Court of First Instance

Plaintiffs-appellees filed a motion to dismiss the appeal and for immediate execution of the judgment on two grounds:

That the Municipal Court’s decision was already final.

That defendant Labyang failed to file a supersedeas bond.

Defendant Labyang opposed the motion, arguing the timely filing of his notice of appeal (filed on July 23, 1963) and contesting the need for a supersedeas bond on the basis that no reasonable rental value had been fixed by the Municipal Court.

Dismissal and Subsequent Reconsideration

On December 14, 1963, the Court of First Instance dismissed the appeal on the basis that the Municipal Court’s decision was received by Labyang’s counsel on July 2, 1963, rendering his filing on July 25, 1963 late.

On January 12, 1964, defendant-appellant filed a "Motion for Reconsideration and Petition for Relief from Judgment," alleging:

His counsel had collected the Municipal Court’s decision only on July 5, 1963 from the Iloilo City Post Office.

Notification of the judgment to him was delayed due to postal inefficiency, which affected timely preparation of the appeal bond and docket fees.

Judge Perfecto Querubin later lifted the dismissal order on March 21, 1964, giving due course to the appeal despite the earlier dismissal, remarking on the earnest efforts by Labyang and his counsel complicated by postal delays.

Plaintiffs, represented by new counsel, subsequently filed another motion to dismiss and for immediate execution on November 26, 1966, relying on the ground that the issues had already been fully pleaded and resolved in earlier orders.

Judge Ramon Blanco denied this subsequent motion and set the case for hearing on February 28, 1967; a later motion for reconsideration by the plaintiffs likewise was denied on December 21, 1967.

Petition for Certiorari and Further Procedural Developments

On March 28, 1969, plaintiffs-appellees filed a petition for certiorari and mandamus with the Court of Appeals, seeking to compel Judge Blanco to dismiss Labyang’s appeal.

The Court of Appeals dismissed the petition, leading to the present appeal.

While the case was pending, on March 11, 1972, counsel for petitioners filed a motion indicating:

Defendant Labyang had already vacated the land in dispute and sold his interest for P300 to Senon Pama.

The case could be considered moot and academic, provided that possession of the land was granted to the petitioners by a writ of execution.

Jurisdictional Issue on the Timeliness of the Appeal

Petitioners contended that the period fixed by the rules for the perfection of an appeal is not only mandatory but also jurisdictional.

They emphasized that compliance with the reglementary period is crucial, as failure to perfect the appeal within this period automatically renders the judgment final and executory.

The case further discusses relevant jurisprudence and rules, notably:

Section 13 of Rule 41, which mandates dismissal of an appeal not perfected within the prescribed period.

The principle laid out in Miranda vs. Guanzon, Galima vs. Court of Appeals, and other cases emphasizing that reglementary periods are jurisdictional in nature.

Issue:

Whether the notice of appeal and appeal bond were filed within the mandatory, jurisdictional period as required by law.

The discrepancy in dates (receipt of the Municipal Court’s decision on July 2 vs. July 15) creates a conflict regarding timeliness.

Whether the alleged postal delay constitutes a valid excuse for the filing being deemed late.

Whether the Court of First Instance had jurisdiction to entertain and rule on:

The Motion for Reconsideration and Petition for Relief from Judgment filed by defendant Labyang’s counsel on January 12, 1964.

The subsequent motions and the alleged effects of postal inefficiency on the perfection of the appeal.

Whether, in view of the lapse of time and procedural defaults, the Municipal Court’s judgment should be reinstated as final and executory, thereby dismissing Labyang’s appeal.

The broader implication of the rule that the perfection of an appeal within the reglementary period is jurisdictional and mandatory, regardless of external factors such as postal delays.

Ruling:

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Ratio:

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Doctrine:

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