G.R. No. 155650 - Manila International Airport Authority vs. Court of Appeals

In June 1975, respondents filed an action for reconveyance and recovery of parcels of land against petitioner Manila Memorial Park Cemetery, Inc. and co-defendants including United Housing Corporation, Victorino Hernandez, and the heirs of Aurelio de Leon and Nicolas Gatchalian.
After protracted litigation, the trial court, through then Presiding Judge Efricio B. Acosta, dismissed the complaint on 17 June 1983 for lack of merit, stating that the claims were barred by the statute of limitations and laches.
Respondents received a copy of the dismissal decision on 04 July 1983.

On 19 July 1983, within the prescribed fifteen-day appeal period, respondents filed a motion for new trial and/or reconsideration instead of a notice of appeal.
The trial court denied the motion for reconsideration on 03 October 1989, with respondents receiving the order on 28 November 1989.
Subsequently, on 07 December 1989, respondents filed a notice of appeal after the trial court had given due course to the appeal on 11 December 1989.
The appellate records were delayed, partly because of missing stenographic notes, which compounded the procedural irregularity in perfecting the appeal.

On 23 April 1996, the trial court convened a conference to complete the record, but the missing transcript of stenographic notes remained unsubmitted.
On 28 February 1997, respondents filed a motion for a new trial seeking to retake and present missing testimonial and documentary evidence, contending that the absence of notes could no longer be remedied due to the retirement and unavailability of the stenographers.
On 22 April 1997, petitioner filed a motion to dismiss the appeal and an opposition to the respondents’ motion for new trial, arguing the appeal was filed out of time and that the remedy for a new trial was erroneously pursued after the lapse of the appeal period.
The trial court, in its order dated 16 July 1997, granted respondents’ motion for new trial and declared the notice of appeal moot, simultaneously dismissing petitioner’s motion to dismiss the appeal on grounds of laches and futility.

Dissatisfied with the trial court’s resolution, petitioner elevated the issue via a petition for certiorari to the Court of Appeals, challenging the trial court’s actions as capricious and an exercise of grave abuse of discretion.
The petition raised issues regarding the timeliness of the appeal, the jurisdictional nature of perfecting an appeal, and the propriety of allowing a new trial after judgment had become final and executory.
The Court of Appeals, in its decision dated 18 May 1998, dismissed the petition on the ground of petitioner's laches, emphasizing that petitioner’s delay in raising the issue prevented it from assailing the notice of appeal which had been given due course earlier.

Whether the perfection of an appeal within the prescribed reglementary period is a jurisdictional requirement and can be challenged at any time.

Petitioner contends that compliance with the statutory period for perfecting an appeal is indispensable and any delay renders the appeal invalid.
Respondents argue that their notice of appeal, though filed after a motion for reconsideration, was acceptable under the rules governing the interruption of the appeal period.

Whether petitioner is estopped from contesting the timeliness of the respondents’ notice of appeal after an eight-year delay.

The issue examines if petitioner’s prolonged inaction prior to raising the question constitutes a waiver or estoppel of its right to challenge the appeal’s timeliness.
The court must determine if applying the doctrines of laches and estoppel is appropriate given the extraordinary delay.

Whether the trial court erred in sanctioning the respondents' motion for a new trial, thereby allowing the case to be retried on merits, despite the issuance of a final judgment.

The contention arises over whether the trial court had acting jurisdiction after the judgment had become final and executory.
The propriety of the trial court’s order in retrospect, especially considering the implications for the appellate review process, is critically questioned.