Case Summary (G.R. No. 50654)
Case Background and Procedural History
In Civil Case No. 971, Mata filed a complaint against Armigos for damages and attorney's fees. The Municipal Court ruled in favor of Mata, after which Armigos received the decision on June 8, 1977. He filed a notice of appeal the following day, June 9, 1977. Armigos purported that he finally perfected his appeal by June 24, 1977, fulfilling all procedural requirements, including the filing of an appeal bond. However, the Court of First Instance of Davao del Sur (Branch V) deemed his appeal as filed beyond the reglementary period, leading to its dismissal.
Legal Arguments Presented
Armigos contended that the computation of the period for appealing should start from the exact hour he received the municipal court's decision. He argued that from June 8 until June 24, only fifteen days elapsed, thus the appeal was timely. This unique interpretation of the computation period was flatly rejected by the Court of Appeals, which emphasized practical concerns regarding the reliability of determining precise times for receiving court decisions. The appellate court supported its decision by citing judicious precedents, reinforcing a more conventional understanding of appeal timelines.
Court of Appeals Decision and Rationale
The Court of Appeals dismissed Armigos’ appeal and denied his motion for reconsideration filed subsequently. The Court posited that the proper computation of periods for appeal follows established legal principles where the first day is excluded, and the last day is included. The Court distinguished between the different legal provisions governing the computation of time, asserting that these rules maintain judicial integrity and ensure clarity in procedural matters.
Judicial Discretion and Appeal Timeliness
The Court recognized that while procedural rules should ideally empower parties to pursue justice, they must also be adhered to with diligence. The Court emphasized that the granting of out-of-time appeals requires justifiable reason, warning that such discretion is limited and contingent on tangible evidence or circumstances j
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Case Reference
- Citation: 258-A Phil. 561
- Division: Second Division
- G.R. No.: 50654
- Date of Decision: November 06, 1989
Parties Involved
- Petitioner: Rudy Gleo Armigos
- Respondents: Court of Appeals, Cristito Mata, Judge L. D. Carpio (in his capacity as Judge of the Court of First Instance of Davao del Sur, Branch V)
Procedural History
- The case is a review on certiorari of the decision of the Court of Appeals, which dismissed the petition of Rudy Gleo Armigos challenging the decision of the Court of First Instance of Davao del Sur regarding his appeal.
Undisputed Facts
- Cristito Mata filed a complaint against Rudy Gleo Armigos in the Municipal Court of Digos, Davao del Sur, for damages and attorney's fees, which was docketed as Civil Case No. 971.
- The Municipal Court ruled in favor of Mata, and Armigos received the decision on June 8, 1977.
- Armigos filed a notice of appeal on June 9, 1977, and completed the requirements for the appeal, including an appeal bond and payment of the docket fee, by June 24, 1977.
- The Court of First Instance dismissed Armigos's appeal, claiming it was filed beyond the reglementary period.
Legal Issues Presented
- Armigos contended that the computation of the 15-day period to appeal should begin at the exact hour he received the decision.
- The Court of Appeals rejected this interpretation, leading to Armigos's motion for reconsideration, which was also denied.
Court of Appeals Rulings
- The Court of Appeals dismissed Armi