G.R. No. 141524 - Neypes vs. Court of Appeals

Petitioners (Domingo Neypes et al.) filed before the Regional Trial Court (RTC), Branch 43, Roxas, Oriental Mindoro, an action for annulment of judgment and titles of land and/or reconveyance and/or reversion with preliminary injunction.
Respondents: Bureau of Forest Development, Bureau of Lands, Land Bank of the Philippines (LBP), and the heirs of Bernardo del Mundo (Fe, Corazon, Josefa, Salvador, Carmen).

Various motions filed by parties, including petitioners’ motion to declare respondents in default and respondents’ motions to dismiss.
RTC Order (May 16, 1997):

Granted petitioners’ motion to declare the Bureau of Lands and Bureau of Forest Development in default; denied as to the del Mundo heirs.
Denied LBP’s motion to dismiss for lack of cause of action.
Denied heirs’ motion to dismiss based on prescription.

RTC Order (February 12, 1998): Dismissed petitioners’ complaint on the ground of prescription. Petitioners received this on March 3, 1998.
Petitioners filed a motion for reconsideration on March 18, 1998; RTC denied it by Order dated July 1, 1998, received by petitioners on July 22, 1998.
Petitioners filed a notice of appeal on July 27, 1998; paid appeal fees on August 3, 1998. RTC denied the appeal as tardy (Order August 4, 1998), a denial petitioners’ later motion for reconsideration of which was likewise denied (September 3, 1998).

Petitioners filed a petition for certiorari and mandamus (Rule 65) before the Court of Appeals (CA), arguing timely appeal from the July 22, 1998 order.
CA Decision (September 16, 1999): Dismissed petition for being filed out of the 15-day reglementary period counted from March 3, 1998 order. Motion for reconsideration denied (January 6, 2000).
Petitioners thereafter filed a petition for review under Rule 45 before the Supreme Court, assigning errors on the reckoning of the appeal period, definition of “final order,” and applicability of Denso, Inc. v. IAC.

Whether petitioners seasonably filed a notice of appeal and paid docket fees within the 15-day reglementary period.
Whether the CA erred in ruling that petitioners’ appeal was out of time despite receiving the “final order” on July 22, 1998.
Whether the term “final order” under Rule 41, Section 3, refers to the February 12, 1998 dismissal order or the July 1, 1998 order denying the motion for reconsideration.
Whether the decision in Denso, Inc. v. IAC applies to this case under the 1997 Rules of Civil Procedure.