Title
Ernesto Oppen, Inc. vs. Court of Appeals
Case
G.R. No. L-29986
Decision Date
Apr 17, 1984
Plaintiff's appeal dismissed due to one-day filing delay caused by clerk's illness; Supreme Court ruled in favor, prioritizing substantial justice over technicalities.

Case Summary (G.R. No. L-29986)

Procedural Background

The procedural history began when the defendants filed an answer that included a counterclaim against the plaintiff. Following a pre-trial, which the plaintiff failed to attend, the court declared Ernesto Oppen, Inc. non-suited. Consequently, the defendants presented their evidence ex parte, leading to a judgment in their favor that included moral damages, attorney’s fees, and costs. Both parties subsequently sought reconsideration of this decision, which was denied.

Filing for Appeal

Upon receiving the unfavorable decision, the plaintiff filed a notice of appeal alongside a motion to extend the duration for filing the record on appeal and an appeal bond. The trial court initially denied the motion for extension, citing a one-day delay, which was deemed significant enough for the disapproval of the record on appeal and the bond.

Motion for Reconsideration

Following the denial, the plaintiff submitted a motion for reconsideration, justifying the delay due to the illness of the counsel's filing clerk. The trial court ultimately decided to reconsider its prior ruling, granting the extension and approving the appeal bond and amended record on appeal.

Court of Appeals Proceedings

Subsequent to the appeal's docketing, the defendants moved to dismiss the appeal, again citing the untimely filing of the record on appeal and bond. The Court of Appeals granted this motion and affirmed its decision after a motion for reconsideration from the plaintiff, leading to the present petition.

Analysis of Delay

It was established that the delay in filing the extension motion was merely for one day and was supported by a reasonable explanation, which was the illness of the filing clerk. The trial court acted within its rights to grant the motion upon re-evaluation. Importantly, the delay did not prejudice the opposing party, and the record on appeal and appeal bond were eventually filed.

Judicial Discretion and Justice

The decision emphasized the principle that courts should prioritize substantive justice over procedural technicalitie

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