Case Summary (G.R. No. 162518)
RTC Decision and Procedural History
On February 21, 2003, the RTC rendered its decision acquitting Generoso Damaso in the criminal cases due to insufficient evidence and ruled against petitioner in the civil case, ordering him to pay moral and exemplary damages, as well as costs of suit. Petitioner filed a motion for reconsideration on March 6, 2003, but it was denied on May 9, 2003. Subsequently, petitioner filed a notice of appeal on May 29, 2003, which the RTC denied for being filed out of time, relying on petitioner’s judicial admission that he received the decision on the date of promulgation, February 21, 2003. Petitioner’s subsequent motion for reconsideration was also denied.
Court of Appeals’ Ruling
Petitioner elevated the matter to the Court of Appeals (CA), which dismissed the petition. The CA held that petitioner was judicially bound by his admission of receipt of the RTC decision on February 21, 2003, meaning the appeal period had lapsed by the time he filed the notice of appeal on May 29, 2003. The CA likewise denied petitioner’s motion for reconsideration.
Issues Raised in the Petition for Review on Certiorari and Grounds
The petitioner contended that the CA erred in ruling that his appeal period had lapsed, asserting that such ruling was based on a misapprehension of facts and contradicted by evidence on record. Furthermore, petitioner argued that the CA failed to identify the specific evidence supporting its conclusions and neglected facts that could have justified a different ruling.
Applicable Law: The 1987 Philippine Constitution and Procedural Rules
As the case’s decision date is post-1990, the 1987 Philippine Constitution and the Revised Rules of Court govern the proceedings, specifically Rule 41 on appeals and Rule 45 on certiorari.
Supreme Court’s Analysis on the Appeal Period: The “Fresh Period Rule”
The Supreme Court relied on its landmark rulings in Neypes v. Court of Appeals and subsequent decisions, which clarified the computation of the appeal period under Rule 41, Section 3. It established a “fresh period rule,” allowing parties who have filed a motion for reconsideration or new trial to file a notice of appeal within fifteen (15) days from receipt of the denial order, thereby creating a new and independent appeal period.
The Court emphasized that this rule harmonizes existing procedural rules, eliminates confusion as to the starting point of the appeal period, and is procedural in nature, thus applicable retroactively to cases pending at the time of its promulgation without violating vested rights.
Retroactivity and Application to the Present Case
In applying the “fresh period rule” to the instant case, the Supreme Court noted that the petition was pending during the promulgation of the Neypes ruling in 2005. Consequently, the rule applies retroactively, granting petitioner a fresh 15-day period to file his notice of appeal counted from receipt of the denial order on May 19, 2003. As petitioner
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Facts and Procedural Background
- Petitioner Rodrigo Sumiran filed a complaint for sum of money and damages, with a prayer for preliminary attachment, against respondents Spouses Generoso and Eva Damaso before the Regional Trial Court (RTC) of Antipolo City, Branch 73 (Civil Case No. 93-2588).
- Petitioner was also the private complainant in related criminal cases (Criminal Case Nos. 92-8157 and 92-8158) for violation of Batas Pambansa Blg. 22, with Generoso Damaso as the accused.
- Upon respondents’ motion, the civil and criminal cases were consolidated and jointly tried.
- On February 21, 2003, the RTC promulgated its Decision dated January 16, 2003, acquitting accused Generoso Damaso in the criminal cases for insufficiency of evidence.
- The RTC dismissed the civil case against respondents, ruled in favor of the defendants, and ordered petitioner to pay moral damages of ₱50,000, exemplary damages of ₱20,000, and the costs of the suit.
- Petitioner filed a motion for reconsideration on March 6, 2003, asserting receipt of a duplicate original copy of the decision on February 21, 2003.
- The RTC denied the motion for reconsideration on May 9, 2003.
- Petitioner then filed a Notice of Appeal dated May 28, 2003, stating receipt of the decision only on March 8, 2003, and the denial order on May 19, 2003.
- The RTC denied the notice of appeal for being filed out of time on June 2, 2003, reasoning that petitioner received a copy of the decision during its promulgation on February 21, 2003, and that the 15-day appeal period began to run from that date.
- Petitioner filed another motion for reconsideration on June 20, 2003, which the RTC denied on October 1, 2003.
- Petitioner elevated the case to the Court of Appeals (CA) via a petition for certiorari.
- The CA dismissed the petition on December 22, 2003, affirming that the appeal period had lapsed based on petitioner’s judicial admission of receipt on February 21, 2003.
- Petitioner’s motion for reconsideration before the CA was denied on February 20, 2004.
- This petition for review on certiorari to the Supreme Court followed, contesting the CA's ruling on the appeal period and alleging misapprehension of facts and failure to consider relevant evidence.
Issue Presented
- Whether the petitioner's notice of appeal was timely filed based on the "fresh period rule" established by the Supreme Court jurisprudence allowing a new 15-day appeal period counted from receipt of the order denying the motion for reconsideration.
Legal Principles and Jurisprudence Cited
- The Supreme Court recognized the "fresh period rule" in Neypes v. Court of Appeals (2005), which:
- Grants a fresh 15-day period to file a notice of appeal counted from receipt of the order denying a motion for new trial or a motion for reconsideration.
- This rule aims to standardize appeal periods and mitigate confu