Caina v. Court of Appeals
REITERATIONFacts
The Antecedents: Leoncio Caina and Jacinta Caina (plaintiffs) filed a complaint against Elena Peralta Vda. de Caina and others (defendants), successors of Valeriano Caina, for ownership of Lot No. 222-C. Raymunda Damaso intervened. Procedural History: The Court of First Instance of Rizal, on April 24, 1957, dismissed the plaintiffs' complaint and declared the defendants the legal owners of Lot No. 222-C, ordering the annotation of a deed of sale. The counterclaim for damages was dismissed, but P500.00 in attorney's fees was awarded to the defendants. The plaintiffs received the judgment on May 9, 1957. On June 5, 1957, they filed a record on appeal but without an appeal bond. On June 10, 1957, the defendants moved for execution. On June 14, 1957, the plaintiffs opposed the motion, praying to appeal as paupers or to be granted ten days to file an appeal bond. On July 19, 1957, the trial court granted the motion for execution and denied the plaintiffs' motions regarding pauper appeal and extension to file a bond. The plaintiffs' subsequent motions for reconsideration were denied on December 10, 1957, and January 18, 1958. The Petition: The plaintiffs filed a petition for certiorari and mandamus in the Court of Appeals, seeking to annul the trial court's orders denying their motions and granting execution, and to compel the court to allow their appeal. On September 29, 1957, the Court of Appeals granted the writs. The defendants' motion for reconsideration was denied on October 21, 1958. The defendants then filed an appeal by certiorari with the Supreme Court, assailing the Court of Appeals' judgment and resolution, alleging grave abuse of discretion and lack of jurisdiction. They also prayed for a writ of preliminary injunction.
Issue(s)
Whether the Court of Appeals committed a grave abuse of discretion amounting to lack of jurisdiction in granting the writs of certiorari and mandamus. Whether the trial court erred in denying the plaintiffs' motion to appeal as paupers and their motion for an extension of time to file an appeal bond, and in ordering the execution of the judgment.
Ruling
The Supreme Court set aside the judgment of the Court of Appeals dated September 29, 1958, and made the writ of preliminary injunction previously issued permanent. The costs were against the respondents Leoncio Caina and Jacinta Caina.
Ratio Decidendi
On Issue 1: The Supreme Court held that the Court of Appeals committed a grave abuse of discretion amounting to lack of jurisdiction. The appellate court erred in granting the writs of certiorari and mandamus because its premise that the respondents' motion dated May 31, 1957, was filed within the reglementary period for appeal was factually incorrect. The record showed that the motion was filed on June 14, 1957, which was beyond the thirty-day reglementary period that ended on June 8, 1957. Therefore, the judgment of the trial court had already become final and executory. On Issue 2: The Supreme Court found that the trial court acted correctly in denying the plaintiffs' motions and ordering the execution of the judgment. Since the plaintiffs failed to perfect their appeal within the reglementary period by not filing an appeal bond and filing their motion for extension beyond the deadline, the judgment had attained finality. Consequently, the trial court's duty to order the execution of the judgment was ministerial, and it did not err in doing so. The Court of Appeals' pronouncement that the trial court should have considered the respondents' prayer for extension was based on a misapprehension of the facts regarding the timeliness of the filing.
Main Doctrine
The Supreme Court reiterated that once a judgment becomes final and executory, the trial court's duty to order its execution is ministerial. The Court emphasized that the failure to perfect an appeal within the reglementary period, specifically by not filing an appeal bond or a motion to appeal as a pauper within the prescribed thirty-day period, results in the judgment becoming final and executory. Consequently, the Court of Appeals erred in granting writs of certiorari and mandamus to compel the trial court to give due course to an appeal that was not perfected on time.