Case Digest (G.R. No. 4800)
Facts:
The case of Potenciano Aragon vs. The Hon. Manuel Araullo, as Judge of the Court of First Instance of Manila, et al., arose from an action initiated by the Orden Tercera de San Francisco against Potenciano Aragon in November 1906. The plaintiff sought to recover possession of a house that had been leased to Aragon and demanded payment for overdue rents. The justice of the peace ruled in favor of the plaintiff, prompting Aragon to appeal the decision to the Court of First Instance. The appeal remained unresolved by the end of 1907 and was only decided on February 7, 1908. Following the ruling, Aragon filed exceptions to the decision, requested a new trial, and submitted a bill of exceptions to facilitate his appeal. However, on April 11, 1908, the Court of First Instance denied the appeal and refused to certify the bill of exceptions, citing Section 16 of Act No. 1627 of the Philippine Commission, which stated that the decision in the second instance was not appealable. Subseq...
Case Digest (G.R. No. 4800)
Facts:
Parties Involved:
- Plaintiff: Potenciano Aragon
- Defendants: The Hon. Manuel Araullo, as Judge of the Court of First Instance of Manila, et al.
Nature of the Case:
- The Orden Tercera de San Francisco filed a case against Potenciano Aragon in November 1906 before the justice of the peace of Manila. The plaintiff sought to recover possession of a house leased to Aragon and to collect overdue rents.
Procedural History:
- The justice of the peace ruled in favor of the plaintiff. Aragon appealed the decision to the Court of First Instance.
- The appeal was pending at the close of 1907 and was decided on February 7, 1908, by the Court of First Instance, which also ruled in favor of the plaintiff.
- Aragon filed a motion for a new trial and presented a bill of exceptions to appeal the decision. However, the Court of First Instance, citing Section 16 of Act No. 1627, overruled the appeal and refused to certify the bill of exceptions.
Legal Context:
- Section 16 of Act No. 1627, which took effect on July 1, 1907, limited appeals to two instances for cases originating in justice of the peace courts, unless expressly stated otherwise.
Issue:
- (Unlock)
Ruling:
- (Unlock)
Ratio:
Procedural Laws Apply to Pending Cases:
- Procedural laws, unless expressly stated otherwise, apply to cases pending at the time of their enactment. Section 16 of Act No. 1627, being procedural, applied to Aragon's case, which was pending when the law took effect.
Right to Appeal is Statutory:
- The right to appeal is not inherent but is a privilege granted by law. The law in force at the time of the decision determines whether an appeal is permissible.
Limitation of Appeals to Two Instances:
- Act No. 1627 limited appeals to two instances for cases originating in justice of the peace courts, except in cases expressly provided by the law. Since Aragon's case did not fall under any exception, no further appeal was allowed.
Jurisdiction of the Supreme Court:
- The Supreme Court lacks jurisdiction to hear appeals not permitted by the law in force. Since Act No. 1627 repealed the provision allowing appeals in third instance, the Court could not entertain Aragon's appeal.