Miranda v. Guanzon
REITERATIONFacts
1. The Antecedents: The underlying dispute originated from Civil Case No. 8465 in the Court of First Instance of Manila, where Alfredo Miranda, as petitioner, obtained a favorable judgment against David Guanzon. The nature of the case appears to fall under the purview of the Workmen's Compensation Act, as indicated by the complaint's averments and the lower court's findings. 2. Procedural History: Following the Court of First Instance's judgment on March 8, 1951, respondent David Guanzon received a copy on March 17, 1951. Guanzon filed his record on appeal on April 7, 1951, nineteen days after receiving the judgment, which was approved by the lower court. Petitioner Alfredo Miranda subsequently filed a motion to dismiss the appeal in the Court of Appeals on June 9, 1951, arguing it was not perfected within the reglementary period. The Court of Appeals denied this motion on June 11, 1951, citing petitioner's failure to object in the lower court and the prejudice to the appellant after the record on appeal had been printed. A motion for reconsideration was also denied. 3. The Petition: This case reaches the Supreme Court via a petition for certiorari seeking to overturn the Court of Appeals' resolution denying the motion to dismiss the appeal. Petitioner contends that the Court of Appeals erred in not dismissing the appeal, arguing that the failure to perfect the appeal within the fifteen-day reglementary period prescribed for Workmen's Compensation cases under Section 17, Rule 41 of the Rules of Court is mandatory and jurisdictional, and thus cannot be waived. Petitioner asserts that the appeal was filed out of time, divesting the appellate court of jurisdiction.
Issue(s)
Whether the Court of Appeals erred in denying the motion to dismiss the appeal on the ground that the appeal was not perfected within the reglementary period. Whether the failure to object to the perfection of an appeal in the lower court constitutes a waiver of the right to question the same in the appellate court.
Ruling
The resolution of the Court of Appeals is set aside, and the appeal interposed by respondent is dismissed.
Ratio Decidendi
On the issue of whether the Court of Appeals erred in denying the motion to dismiss the appeal on the ground that the appeal was not perfected within the reglementary period: The Supreme Court held that the appeal was indeed perfected out of time. The case was determined to fall within the purview of the Workmen's Compensation Act. Section 17, Rule 41 of the Rules of Court mandates that appeals in such cases shall be perfected within fifteen days. Respondent received the judgment on March 17, 1951, and filed his record on appeal on April 5, 1951, which is nineteen days later, thus exceeding the reglementary period. The Court emphasized that the filing of a record on appeal was not even necessary, as the original record should have been transmitted. Regardless, the appeal was perfected beyond the statutory period. On the issue of whether the failure to object to the perfection of an appeal in the lower court constitutes a waiver of the right to question the same in the appellate court: The Supreme Court ruled that this claim is untenable. The requirement for perfecting an appeal within the reglementary period is not merely mandatory but jurisdictional. A failure to comply with this period renders the judgment final. The certification of the record on appeal thereafter cannot revive the jurisdiction that has been lost. Such dismissal can be effected even after the case has been elevated to the Court of Appeals, as provided in Section 1(a), Rule 52. The Court cited several cases, including Roman Catholic Bishop of Tuguegarao vs. Director of Lands, to support the principle that failure to perfect an appeal within the prescribed time causes the judgment to become final and the lost jurisdiction cannot be restored. The Court distinguished the cited cases of Slade Perkins vs. Perkins and Luengo and Martinez vs. Herrero, stating that the objections deemed waived in those cases did not affect the jurisdiction of the court, unlike the present situation where the timeliness of the appeal is a jurisdictional matter.
Main Doctrine
The failure to perfect an appeal within the reglementary period is jurisdictional and cannot be waived, even if the motion to dismiss is filed late or after the record on appeal has been printed.