Case Summary (G.R. No. L-15616)
Case Overview and Background
On March 25, 1958, the Court of First Instance of Negros Occidental rendered a decision in Civil Case No. 4352, ordering the petitioners to pay Siguenza the sum of P7,500, with legal interest from the date of the filing of the complaint, along with P1,000 for attorney's fees. Following the decision, the court attempted to serve the ruling to the petitioners' counsel, Atty. Jose Macasa, on March 29, 1958, but he refused to accept the service. Subsequent service attempts were also unsuccessful, leading to the decision being sent via registered mail, which went unclaimed until April 26, 1958.
Timeline of Procedural Events
After the decision was rendered, Siguenza filed a motion for execution on May 8, 1958. Meanwhile, the petitioners filed their notice of appeal and appeal bond on May 19, 1958. Siguenza contested the validity of the appeal on the grounds that it had not been perfected in the required timeframe. The court ordered the motion for execution granted on June 5, 1958, which was followed by the dismissal of the petitioners’ appeal on July 26, 1958. The petitioners' motion for reconsideration was denied on August 9, 1958.
Court of Appeals Proceedings
On September 17, 1958, the petitioners sought a writ of mandamus from the Court of Appeals, challenging the dismissal of their appeal based on alleged non-receipt of the registry notices. The Court of Appeals concluded that the petitioners’ notice of appeal was filed outside the reglementary period, stating that the period to appeal commenced after five days from the first registry notice sent on March 31, 1958. The court’s findings were based on the testimony of the mailman, Dominador Pedria, who indicated that the notices were delivered to an individual residing at Atty. Macasa's address, thereby establishing that the notices were indeed received.
Legal Issue and Resolution
The central legal issue was whether the petitioners' appeal was timely filed. The Court of Appeals determined it was not, highlighting that an elapsed period exceeding the prescribed thir
...continue readingCase Syllabus (G.R. No. L-15616)
Case Citation
- G.R. No. L-15616
- Date of Decision: September 19, 1961
- Court: Supreme Court of the Philippines
- Justices: Concepcion, C.J., Padilla, Labrador, Reyes, J.B.L., Paredes, Dizon, De Leon, Natividad, JJ. (Bautista Angelo, J. on leave)
Parties Involved
- Petitioners: Lourdes Aldecoa, Barbara Zamora, Augusto E. Salazar
- Respondents: Hon. Francisco Arellano (Judge of the Court of First Instance of Negros Occidental, Branch I), Pedro G. Siguenza
Background of the Case
- The case originates from a decision rendered on March 25, 1958, by Judge Francisco Arellano in Civil Case No. 4352, titled "Pedro G. Siguenza vs. Lourdes Aldecoa, Barbara Zamora and Augusto E. Salazar."
- The decision ordered the petitioners to pay Siguenza the sum of ₱7,500, with interest from the filing date of the complaint, and an additional ₱1,000 for attorney's fees.
Service of Notice
Initial Service Attempts:
- On March 29, 1958, a court stenographer attempted to serve a copy of the decision to Atty. Jose Macasa, counsel for the petitioners, but he refused to accept it.
- A subsequent attempt to serve the decision to Carlos Macasa, Atty. Macasa's brother, was also refused as he insisted that the copy should be delivered to Atty. Macasa personally.
Registered Mail:
- Following the refusals, the decision was sent to Atty. Macasa via registered mail on March 31, 1958, with a registry notice issued.
- Atty. Macasa failed to claim the registered letter, prompting two additional notices sent on April 7 and April 17, 1958.
- Carlos Macasa finally claimed th