G.R. No. L-5558 - Manabat vs. Aquino

Enrique D. Manabat and his wife, petitioners, were defendants in a suit regarding a promissory note before the peace court of Tarlac, Tarlac.
The petitioners denied the liability based on the allegation of usury.
Their failure to appear and present evidence led to an order compelling them to pay the sum of P1,261.74 plus interest, based on proofs introduced by the plaintiffs, Alejandra L. de Roxas and Claudio Roxas.

Upon receiving notice of the decision on September 7, 1951, the petitioners transmitted their notice of appeal on September 22, 1951.

The appeal notice was sent by registered mail.
It was accompanied by a postal money order for P16 as docket fees and a surety bond in the sum of P30 as appeal bond.

The appeal papers were received at the peace court on September 24, 1951 and subsequently forwarded to the court of first instance, where the appeal was docketed as Civil Case No. 638.

The appeal documents, having been received on September 24, were two days late, as the 15-day period (expiring on September 22) had lapsed.
The appeal was deemed frivolous and allegedly interposed solely to cause delay.

The judge of first instance dismissed the appeal for lack of jurisdiction, specifically refusing to apply Section 1, Rule 27 of the Rules of Court, which states that the "date of the mailing" (as evidenced by the post-office registry receipt) shall be considered as the date of filing.

The petitioners relied on Section 1, Rule 27, contending that the date of mailing (September 22) should be considered as the filing date thereby rendering the appeal timely.
The respondent judge contended that the rule is applicable only to courts of first instance, not extending to inferior courts like the peace court, as emphasized by Section 19, Rule 4.
Prior jurisprudence was cited to illustrate that rules not expressly enumerated in Section 19, Rule 4 have been applied in inferior courts, thus supporting a uniform application of the rules.

The Supreme Court analyzed whether the enumeration in Section 19, Rule 4 was intended to be exclusive.
The Court held that excluding Rule 27 by mere enumeration would lead to anomalies such as disregarding established principles in other rules (e.g., Rules 123, 131, 2, and 3).
The Court favored maintaining uniformity in the rules by applying Section 1, Rule 27 to inferior courts, thereby deeming the appeal papers as filed on the mailing date.

Whether the appeal filed by the petitioners was perfected within the 15-day period as required by Section 2, Rule 40 of the Rules of Court.

This depends on whether the filing date is determined by the date of mailing (September 22) or the actual receipt date (September 24).

Whether Section 1, Rule 27 of the Rules of Court, which provides that the "date of mailing" is the filing date, is applicable to inferior courts such as the justice of the peace courts.

The respondent argued that the enumeration in Section 19, Rule 4 excludes the application of this rule to inferior courts.
The petitioners contended that a strict interpretation of the enumeration would produce undesirable consequences and disrupt uniform procedural standards.