Title
Salaveria vs. Albindo
Case
G.R. No. 15486
Decision Date
Jul 18, 1919
Both plaintiffs and defendants appealed a lower court judgment. The Supreme Court dismissed both appeals for failure to pay required filing fees within the prescribed period, upholding strict compliance with procedural rules to prevent delays.

Case Summary (G.R. No. 15486)

Procedural Background

Both parties appealed to the Supreme Court following the judgment from the lower court. The plaintiffs’ attorney filed a motion to dismiss the defendants' appeal, claiming it had been abandoned due to the defendants' failure to pay filing fees within the prescribed timeframe. However, upon reviewing the records, the Supreme Court found that both parties had indeed failed to pay the required fees, leading to the dismissal of both appeals.

Relevant Legal Provisions

The pertinent law addressing the payment of fees in appeals is found in Section 787 of the Code of Civil Procedure, which stipulates that the court may refuse to proceed with an action or may dismiss an appeal for failure to pay fees within a reasonable time after notice. This section serves as a basis for the court’s decision concerning the abandonment of the appeals due to non-compliance with fee payment requirements.

Practices Prior to New Rules

Historically, the court allowed records to remain in its archives indefinitely if appellants did not pay necessary fees. However, recognizing the inefficiency stemming from this practice, the court implemented new rules aimed at expediting justice and discouraging delay tactics by specifying time limits for fee payments.

New Rules Implementation

The Supreme Court adopted new rules effective January 1, 1919, designed to ensure that appeals progressed without undue delay. Notably, under Section 14(b) of these new rules, if an appellant fails to pay the docketing fee within ten days of receiving notice of the transmission of the bill of exceptions or record on appeal, the appeal is automatically deemed abandoned and dismissed without requiring motion.

Court's Conclusion

In light of the failure of both pa

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