Case Digest (G.R. No. 224438-40)
Facts:
Republic of the Philippines represented by the Presidential Commission on Good Government (PCGG) and Mid-Pasig Land Development Corp., G.R. Nos. 224438-40, September 03, 2020, First Division, Reyes, J., Jr., writing for the Court.The petitioners (the Republic as represented by the PCGG and Mid-Pasig Land Development Corporation) filed three separate unlawful detainer and damages suits in the Metropolitan Trial Court (MeTC) of Pasig City, Branch 72, against respondents Augustus Albert V. Martinez (doing business as “Uncle Moe’s Shawarma Hub”), City Golf Development Corporation, and Geek’s New York Pizzeria, Inc.. The MeTC dismissed the complaints in three Decisions dated March 15, 2013.
On May 20, 2013 petitioners received copies of the MeTC Decisions. On May 28, 2013 petitioners (through the Office of the Solicitor General) filed Notices of Appeal addressed to the Court of Appeals (CA) instead of to the Regional Trial Court (RTC). On June 3–4, 2013 petitioners filed a Manifestation and Motion with an attached corrected Notice of Appeal (which they claim was sent by registered mail on June 4, 2013). The MeTC, in a twin Order dated June 18, 2013, allowed substitution of the May 28 notice with the corrected notice and transmitted the records to the RTC.
Respondents moved to dismiss the appeals before the RTCs (raffled to Branches 155 and 67). The RTC of Pasig City, Branch 155 (Order dated February 7, 2014) and Branch 67 (Order dated April 21, 2014) denied the motions, finding the appeals were perfected in time—relying on the MeTC’s June 18, 2013 Order and on the dated registry stamp on the pleadings. The RTCs also denied subsequent motions for reconsideration (orders dated May 30, 2014 and July 10, 2014).
Respondents then filed separate Petitions for Certiorari with the Court of Appeals (CA) — consolidated as CA-G.R. SP Nos. 135972, 136895 and 136896 — alleging the RTCs committed grave abuse of discretion by giving due course to belated appeals. In its Decision dated November 4, 2015, the CA held that petitioners’ corrected Notices of Appeal were filed only on June 7, 2013 (beyond the 15-day period), criticized petitioners’ failure to attach the original registry envelopes/receipts, found discrepancies in registry receipt numbers, and concluded the RTCs gravely abused their discretion; the CA dismissed the appeals and enjoined the RTCs from proceeding. The CA denied reconsideration in...(Subscriber-Only)
Issues:
- Did the Court of Appeals err as a matter of law in finding that the Regional Trial Courts committed grave abuse of discretion when they ruled that petitioners’ Notices of Appeal were time...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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