Case Summary (G.R. No. L-29416)
Procedural History and Dismissal of Appeal
On November 12, 1965, the trial court ruled in favor of Adoracion Valera de Bringas, ordering the defendants, including Celso Valera, to recognize her as the acknowledged natural child of Francisco Valera. After being served notice of this decision, Celso Valera filed a notice of appeal and an appeal bond on December 14, 1965, later requesting an extension to file his record on appeal, which was granted. However, the Court of Appeals eventually dismissed his appeal due to deficiencies in the record indicating that the appeal had not been perfected within the prescribed reglementary period.
Grounds for Dismissal
The dismissal was based on a failure to properly demonstrate that the original record on appeal was filed within the authorized timeframe. Notably, the amended record did not include the filing date of the original record, which was critical to show compliance with Section 6 of Rule 41 of the Rules of Court. The Court emphasized that the requirement to show timely perfection of an appeal is both mandatory and jurisdictional; failing to do so results in the appellate court lacking jurisdiction to hear the case.
Argument from the Petitioner
Celso Valera contended that the absence of the filing date in the amended record on appeal should not warrant dismissal. He argued that the date of filing is a posterior act and that because the original record on appeal was prepared before it was filed, it needed not to state the date. He also highlighted that the date was stamped on the original document.
Court’s Analysis and Conclusion
The court found that the deficiencies were indeed fatal for the appeal. It ruled that the Amended Record on Appeal submitted to the Court of Appeals failed to provide jurisdictional requirements necessary for a valid appeal. The trial court's certification regarding the filed date did not remedy the shortcomings
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Case Background
- The case arises from an appeal by petitioner Celso Valera against the resolution of the Court of Appeals.
- The Court of Appeals dismissed Valera's appeal, citing "failure of the record on appeal to show on its face that the appeal was perfected" within the mandatory time frame.
- The appeal was dismissed in relation to Section 6 of Rule 41 and Section 1(a), Rule 50 of the Rules of Court.
Initial Proceedings
- On November 12, 1965, the Court of First Instance of Abra issued a decision in Civil Case No. 374.
- The decision recognized Adoracion Valera de Bringas as the acknowledged natural child of Francisco Valera and directed the defendants (including Celso Valera) to acknowledge her as such.
- The counterclaims by Virgilio Valera and Celso Valera were dismissed for lack of merit.
Appeal Process
- A copy of the decision was served to Virgilio Valera and Celso Valera on November 15, 1965.
- Celso Valera filed a notice of appeal and appeal bond on December 14, 1965, requesting a 30-day extension to submit his record on appeal, which was granted on January 14, 1966.
- The lower court later ordered Valera to amend his record on appeal on March 18, 1966.
- The amended record was approved on June 28, 1966, but did not indicate the date the original record was filed.
Court of Appeals Proceedings
- On December 20, 1967, the plaintiffs-appellees filed a motion t