G.R. No. 57204 - Borre vs. Court of Appeals

Petitioners (a group of individuals) filed a complaint against the private respondent, Manotok Services, Inc., seeking recovery of rentals they had paid.
The petitioners alleged that the land leased to them by Manotok was actually public land—part of the Estero de Sunog-Apo and Estero de Maypajo—and that it did not belong to Manotok Services, Inc.
Petitioners based their claim on the theory that the leased property, by virtue of being public domain, could not properly be appropriated or titled by a private entity.

On August 29, 1979, petitioners initiated the complaint, which was later dismissed due to the recognition of the respondent’s title under Pres. Dec. No. 1670.

The decree declared expropriation of the real properties along the Estero de Sunog-Apo in Tondo, Manila, covering Lots Nos. 55-A, 55-B, and 55-C.
The trial court ruled that the ownership of the property vested in Manotok Services, Inc. as recognized by the State.

The first motion, made on December 13, 1980, argued that portions of the property were public and should not have been included in the titles given to the respondent.
A second motion for reconsideration was filed on January 14, 1981, submitting evidence from a subsequent survey showing that the lots petitioners occupied were not covered by the respondent’s titles.
Both motions for reconsideration were denied by the trial court.

Petitioners filed a notice of appeal and a motion for an extension of time to file the record on appeal on January 31, 1981, which was the last day for perfecting their appeal by registered mail.
However, the appeal bond—an essential requirement for perfecting the appeal—was filed only on February 2, 1981, thereby exceeding the prescribed thirty-day period.
As a consequence of the late bond filing, the court dismissed the appeal for non-compliance with the perfection requirements.

Petitioners sought review on certiorari of the Court of Appeals decision which had affirmed the dismissal of their appeal.
The petitioners argued that their late filing of the appeal bond was due to “excusable negligence.”

They claimed an “honest belief” that the Office of the Clerk of Court of the then Court of First Instance of Manila was closed on January 31, 1981 (a Saturday).
They further argued that certain courts on Saturdays were open in the morning solely for the collection of pleadings, invoking the policy of a liberal application of remedial rules.

The petitioners also contended that the basis of the trial court’s dismissal should be reviewed considering the subsequent decision declaring Pres. Dec. No. 1670 null and void ab initio in another case.

Notwithstanding that, the dismissal was ultimately affirmed on the ground that petitioners failed to state a valid cause of action.

An admission by petitioners that they leased the property from Manotok Services, Inc. was critical, as it undermined any claim that the lessor’s title was defective, invoking the doctrine of estoppel against tenants.

Whether the petitioners’ late filing of the appeal bond constituted “excusable negligence” sufficient to relax the strict time limits imposed by the Rules of Court.
Whether the appellant’s belief regarding the closure of the Clerk’s Office on a Saturday was a valid ground for extension.

Whether the perfection of an appeal, including the filing of both the notice of appeal and the appeal bond within the prescribed thirty-day period, is mandatory and jurisdictional.
If failure to comply with these requirements necessitates the dismissal of the appeal, regardless of any subsequent remedial rules or policies favoring liberal application.

Whether the complaint, based on the assertion that the leased property is part of the public domain, sufficiently stated a cause of action.
Whether, by admitting to leasing the property from Manotok Services, Inc., petitioners estopped themselves from contesting the respondent’s title.