Case Summary (G.R. No. 45260)
Factual Background
On September 20, 1999, Reynaldo Santos filed a complaint for a sum of money against Arnulfo Eda, alleging that they had entered into a business arrangement wherein Santos would provide money for Eda to loan out to his officemates. Eda would collect payments and retain a 1% commission, with the remainder returned to Santos. Santos claimed he initially provided P500,000 but was owed P1,200,000, including interest, as Eda failed to remit the collected payments and provided multiple promissory notes regarding the loans. An admitted acknowledgment of debt by Eda was also cited, which further substantiated Santos' claims in his amended complaint.
Judicial Proceedings
The RTC rendered a decision on April 24, 2001, ordering Eda to pay Santos P1,185,030.00 along with legal interest and attorney's fees. Eda's motion for reconsideration was denied, and he subsequently filed a Notice of Appeal. However, the RTC denied the motion due to it being filed beyond the reglementary period. Eda's subsequent motion for reconsideration of the RTC's order was also denied, prompting him to file a petition for certiorari with the CA.
Court of Appeals' Ruling
The CA dismissed Eda's certiorari petition on April 30, 2002, determining that the RTC did not exhibit any grave abuse of discretion in denying Eda's Notice of Appeal due to its untimeliness. The CA asserted that the deadlines for filing appeals are mandatory and jurisdictional, thus rendering the RTC's decision final and executory following the expiration of the appeal period.
Legal Analysis of Jurisdiction
Eda argued that the RTC lacked jurisdiction over the case, claiming his initial investment was only P100,000, thus placing the jurisdiction under the Metropolitan Trial Court as per Republic Act No. 7691. Nonetheless, the jurisdiction is assessed based on the law at the time of complaint filing. The CA clarified that at the time Santos filed his complaint for P1,200,000 on September 20, 1999, which was over five years post the amendment's effectivity, the RTC had proper jurisdiction over the case, thus rejecting Eda's jurisdictional claims.
Appeal Period and Technicalities
Despite acknowledging his Notice of Appeal was late, Eda contended that strict adherence to this timeframe should be relaxed to serve substantial justice. He asserted that payment of the appeal fee essentially perfected his appeal. However, the CA emphasized that the appeal must be filed within the prescri
...continue readingCase Syllabus (G.R. No. 45260)
Case Background
- The case is a petition for review of the Decision dated April 30, 2002, by the Court of Appeals (CA) which dismissed the petition for certiorari filed by the petitioner, Arnulfo Eda.
- The petitioner also contested the Resolution dated September 12, 2002, which denied his motion for reconsideration.
Antecedents
- On September 20, 1999, Reynaldo Santos, the respondent, filed a complaint against Arnulfo Eda for a sum of money in the Regional Trial Court (RTC) of Manila, Branch 29.
- During pre-trial, Eda questioned the RTC's jurisdiction over Santos's claim of ₱100,000.00.
- Santos amended his complaint, detailing a business agreement where he provided funds for Eda to lend to his officemates, with Eda collecting payments and earning a 1% commission.
- Santos asserted that he provided a total of ₱500,000.00 to Eda, who failed to remit collected payments and instead loaned them out again, leading to a total claim of ₱1,200,000.00, including interest.
- The complaint included copies of promissory notes and an instrument where Eda admitted to receiving ₱100,000.00 for lending with a 14% interest rate payable within 60 days.
RTC Proceedings
- Eda countered that the invested amount was only ₱100,000.00 and claimed he could not collect payments due to borrowers abscond