Case Summary (G.R. No. 216788)
Background of the Case
The petitioner filed a Complaint for Specific Performance against the respondents in early 2000, which was dismissed by the RTC on March 5, 2014, after the respondents successfully filed a motion to dismiss following the petitioner’s presentation of evidence. The petitioner’s subsequent motion for reconsideration was denied on May 6, 2014. Following this, the petitioner filed a Notice of Appeal, which the respondents challenged on the grounds that the petitioner lacked a requisite board resolution permitting the appeal.
RTC Orders and Findings
On September 19, 2014, the RTC issued an order expunging the petitioner’s Notice of Appeal for lacking the authority from its Board of Directors, citing Section 12 of Republic Act No. 9904. The RTC acknowledged the payment of the appeal fee within the required time but ruled against the appeal due to the absence of a board resolution. The petitioner’s motion for reconsideration, which included a board resolution purportedly confirming Calilung's authority, was also denied in a December 12, 2014 Order for similar reasons.
Legal Issues Raised
The crux of the appeal revolves around whether the RTC erred in expunging the Notice of Appeal and whether it exercised grave abuse of discretion in doing so. The respondents contended that both RTC Orders were final and thus should not be subject to a certiorari petition. However, the petitioner aimed to challenge the RTC's decisions due to alleged grave abuse of discretion, contending that the RTC acted without jurisdiction.
Court's Analysis and Ruling
The Supreme Court ruled in favor of the petitioner, stating that the RTC’s expungement of the Notice of Appeal constituted a grave legal error. It held that the mere filing of a Notice of Appeal does not require a board resolution to initiate an appeal, as it is not classified as a pleading requiring such a document under the Rules of Court. Moreover, the Court asserted that even if there were procedural flaws in the petitioner’s motion for reconsideration—specifically regarding notice requirements—these should not invalidate the right to appeal.
The Court underscored that
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Case Citation
- G.R. No. 216788
- Date of Decision: November 20, 2017
- Court: Supreme Court of the Philippines, Second Division
- Presiding Justice: Perlas-Bernabe, J.
Parties Involved
- Petitioner: United Interior Manggaan Homeowners Association, represented by its President, Daniel Calilung.
- Respondents: Spouses Edilberto Villon and Helen Pe-Villon, now represented by their heirs: Emee Pe-Villon, Emmanuel Pe-Villon, Elsie Villon-Cabrera, Elma Villon-Austria, and Ellen Ferrero.
Background of the Case
- The petitioner initiated a civil case for specific performance against the respondents in the early 2000s.
- After presenting its case, the respondents filed a motion to dismiss based on a demurrer to evidence, which the RTC granted, dismissing the petitioner's complaint.
- The petitioner sought reconsideration of the dismissal, which was denied, leading to the filing of a Notice of Appeal.
RTC's Rulings
- September 19, 2014 Order: The RTC ordered the expunging of the Notice of Appeal due to the petitioner's alleged lack of authority from its Board of Directors, citing Section 12 of Republic Act No. 9904.
- December 12, 2014 Order: The RTC denied the petitioner's motion for reconsideration, reiterating the lack of authority and the fai