Title
Chan vs. Court of Appeals
Case
G.R. No. 138758
Decision Date
Jul 6, 2000
Spouses engaged a financial consultant for a loan, failed to pay success fee, appealed trial court's ruling but neglected mandatory docket fees; SC upheld trial court, annulling CA's decision.

Case Summary (G.R. No. 138758)

Introduction to Legal Proceedings

William P. Chan filed a petition for certiorari under Rule 65 of the Rules of Court to annul the decision of the Court of Appeals of December 23, 1998, which allowed the Geronimos' appeal. Determined by the need to recover a “success fee” of PHP 2,060,000.00, Chan's complaint in the Regional Trial Court of Makati was prompted by the Geronimos' failure to pay as agreed upon in their contract.

Trial Court Decision

On December 11, 1997, the Regional Trial Court ruled in favor of Chan, ordering the Geronimos to pay the success fee along with interest and attorney’s fees. In response, the Geronimos filed a Notice of Appeal in January 1998, but did not pay the requisite legal fees, leading Chan to file a manifestation highlighting their non-compliance.

Denial of Appeal

Before February 18, 1998, the trial court issued an order denying the Geronimos’ appeal due to their failure to pay the appropriate appellate court fees, thereby rejecting their motion for reconsideration. The Geronimos subsequently sought a review from the Court of Appeals.

Court of Appeals Ruling

On December 23, 1998, the Court of Appeals ruled in favor of the Geronimos, stating that the payment of appellate docket fees to the lower court was non-mandatory based on prior jurisprudence. Thus, it granted their petition, setting aside the trial court’s orders.

Petition for Reconsideration

Chan filed a Motion for Reconsideration against the appellate court’s decision, contending that it wrongly interpreted the applicable rules due to changes introduced by the 1997 Rules of Civil Procedure, which supplanted previous rules.

Supreme Court Decision

The Supreme Court found merit in Chan's petition, emphasizing that the Court of Appeals erred in applying obsolete rules.

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