Title
Cumplido vs. Mendoza
Case
G.R. No. L-20265
Decision Date
Jun 30, 1964
Simeona Cumplido sought mandamus to compel approval of her appeal in a property dispute, but the Supreme Court denied it, ruling her Record on Appeal was filed late, failing to perfect the appeal.

Case Summary (G.R. No. L-20265)

Procedural History

The underlying case began with Civil Case No. 1959 in the CFI of Bulacan, where the court ruled in favor of Cumplido. Following Mendoza's motion for reconsideration, the court amended its judgment, awarding Mendoza half of the property. This amendment prompted Cumplido to file a notice of appeal, along with a cash appeal bond, but issues arose during the appeal process.

Appeal and Bond Issues

Cumplido's motions for an extension of time to file the record on appeal were delayed due to the absence of a presiding judge at the CFI. Although she filed her record on appeal after the original deadline, the trial court later denied it on grounds including failure to serve the cash appeal bond to Mendoza, which was regarded as a technical hurdle.

Legal Standards Governing Appeals

In determining whether Cumplido's appeal was perfected, the Court cited Clarity on the rules concerning appeal processes as outlined in the Rules of Court. It was emphasized that while service of the cash appeal bond could be a defect, it does not by itself invalidate the appeal if the bond was filed within the prescribed timeframe. However, the record on appeal was noted to have been submitted past the allowable period.

Ruling of the Court

The Court found that Cumplido did not establish a clear right to appeal. It also articulated that her delay in filing the record occurred because she failed to confirm the status of her motion for extension with the Clerk of Court. This oversight

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