Title
Alicia Leuterio vs. Court of Appeals
Case
G.R. No. L-35146
Decision Date
Sep 30, 1977
Maria Alicia Leuterio's appeal dismissed by Court of Appeals for omitted filing date in amended record; Supreme Court ruled omission non-fatal, remanded for merits.
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Case Digest (G.R. No. L-35146)

Facts:

Background of the Case

  • The case involves Maria Alicia Leuterio, who filed a petition for confirmation as the acknowledged natural child and legitimated daughter of the decedent Pablo Leuterio.
  • The petition was opposed by Benito Leuterio, the brother of Pablo Leuterio, and now represented by his heirs (private respondents).
  • The Court of First Instance of Pampanga dismissed Maria Alicia's petition on March 10, 1971, which she received on March 18, 1971.

Filing of the Appeal

  • Maria Alicia timely filed her notice of appeal, appeal bond, and original record on appeal within the 30-day reglementary period:
    • Notice of appeal and appeal bond: Filed on March 31, 1971 (13th day).
    • Original record on appeal: Filed on April 15, 1971 (28th day).
  • The original record on appeal was sent to private respondents on the same day, with a notice that it would be submitted for court approval on April 30, 1971.

Amended Record on Appeal

  • Due to objections from private respondents (e.g., clerical errors and single-spacing), the lower court ordered Maria Alicia to file an amended record on appeal within 20 days from August 7, 1971.
  • Maria Alicia complied by filing the amended record on appeal on August 26, 1971 (19th day), which was approved by the lower court on September 9, 1971 without opposition from private respondents.

Appeal to the Court of Appeals

  • The amended record on appeal was elevated to the Court of Appeals, but private respondents moved to dismiss the appeal, arguing that the amended record on appeal did not show the date of filing of the original record on appeal within the reglementary period.
  • The Court of Appeals, by a 4-1 vote, dismissed the appeal, considering the omission a "fatal defect" under the material data rule.

Issue:

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Ruling:

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Ratio:

  1. Substantial Compliance with the Material Data Rule:

    • The Court rejected the rigid application of the material data rule, citing precedents like Berkenkotter vs. Court of Appeals and Diola vs. Court of Appeals.
    • The timely filing of the original record on appeal and the subsequent approval of the amended record on appeal by the lower court indicated substantial compliance with procedural requirements.
  2. Presumption of Timely Filing:

    • The Court presumed that the amended record on appeal was timely filed because it was approved by the lower court after due hearing.
    • The approval of the amended record on appeal carried with it the approval of the original filing, and the omission of the filing date did not render the appeal untimely.
  3. Substantial Justice Over Technicalities:

    • The Court emphasized that procedural rules should not be rigidly applied to defeat the right to appeal, especially when the appeal has been timely perfected.
    • The merits of the case and the ends of justice should prevail over technical defects in the record on appeal.
  4. Applicability of Precedents:

    • The Court applied the principle from Diola vs. Court of Appeals, which held that the omission of certain details in the amended record on appeal is not fatal if the original record on appeal was timely filed.
    • The Court reiterated that amendments to the record on appeal relate back to the filing of the original record on appeal.

Conclusion:

  • The Supreme Court ruled in favor of Maria Alicia Leuterio, setting aside the dismissal of her appeal and remanding the case to the Court of Appeals for resolution on the merits.
  • The Court reaffirmed the principle that procedural rules should serve the ends of justice and not be used to defeat valid appeals.


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