Facts:

The case involves two separate but related petitions: G.R. No. L-34882 and G.R. No. L-35643. The petitioner in G.R. No. L-34882 is J. Amado Araneta, while the respondents are Alfonso Doronila, A. Doronila Resources Development, Inc., and the Court of Appeals. The case was decided on August 24, 1976. The dispute originated from a civil action filed by Araneta in the Court of First Instance of Rizal (now known as the Regional Trial Court) for specific performance of an exclusive option to buy two parcels of land in San Mateo, Rizal, valued at P13,071,215.00, and for damages. The trial court rendered a decision on April 28, 1971, ordering the defendants to clear the properties of encumbrances and execute a deed of sale in favor of Araneta, along with the payment of damages totaling P7,242,250.00 for unrealized profits.

Following the trial court's decision, the Doronilas attempted to appeal to the Court of Appeals. However, Araneta filed a motion to dismiss the appeal, arg...

Facts:

1. Background of the Case:

   • The case involves two consolidated petitions: G.R. No. L-34882 and G.R. No. L-35643.
   • In G.R. No. L-34882, J. Amado Araneta filed a petition for certiorari and prohibition against the Court of Appeals, alleging grave abuse of discretion for refusing to dismiss the appeal of Alfonso Doronila and A. Doronila Resources Development, Inc. (Doronilas) from a decision of the Court of First Instance of Rizal.
   • In G.R. No. L-35643, the Doronilas filed a petition for certiorari and prohibition against the Court of First Instance of Rizal for issuing a writ of execution of the decision, the finality of which was in question in G.R. No. L-34882.

2. Civil Case No. 9856:

   • J. Amado Araneta filed a civil action for specific performance and damages against Alfonso Doronila and A. Doronila Resources Development, Inc.
   • The case involved an exclusive option to buy two parcels of land in San Mateo, Rizal, for a total price of P13,071,215.00.
   • The Court of First Instance of Rizal ruled in favor of Araneta, ordering the Doronilas to clear the properties of liens and encumbrances, execute a deed of sale, and pay damages amounting to over P7.8 million.

3. Appeal to the Court of Appeals:

   • The Doronilas appealed the decision to the Court of Appeals.
   • Araneta moved to dismiss the appeal, arguing that the Doronilas' record on appeal did not show on its face that the appeal was perfected on time, in violation of Section 6 of Rule 41 and Section 1 of Rule 50 of the Rules of Court.
   • The Court of Appeals denied the motion to dismiss, finding that the appeal was perfected on time, and later denied Araneta's motion for reconsideration.

4. Supreme Court Proceedings:

   • Araneta filed a petition with the Supreme Court, arguing that the Court of Appeals should have dismissed the Doronilas' appeal based on previous rulings requiring strict compliance with the "material data rule."
   • The Doronilas countered, citing more recent and liberal rulings by the Supreme Court that relaxed the strict application of the material data rule.

Issue:

1. Timeliness of the Appeal:

   • Whether the Doronilas' amended record on appeal sufficiently complied with the "material data rule" to show that their appeal was perfected on time.

2. Application of the Material Data Rule:

   • Whether the Court of Appeals erred in not dismissing the Doronilas' appeal despite the alleged failure of their record on appeal to show on its face that the appeal was perfected within the reglementary period.

3. Retroactivity of Judicial Decisions:

   • Whether the more liberal rulings of the Supreme Court in cases like Berkenkotter and Pimentel could be applied retroactively to the Doronilas' appeal, which was perfected before those rulings were promulgated.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)