Parsons Hardware Co., Inc. v. Medina
REITERATIONFacts
The Antecedents: Parsons Hardware Co., Inc. filed a civil case against Mariano Medina for a sum of money. The trial court rendered a decision against Medina, who was notified on January 11, 1958. Medina filed his notice of appeal, appeal bond, and record on appeal on February 2, 1958. Procedural History: The trial judge, upon objection by Parsons Hardware Co., Inc., ordered Medina to amend his record on appeal by including specified pleadings and correcting typographical errors within five days. Medina received this order on February 15, 1958. He failed to file the amended record on appeal within the five-day period. The hearing was reset to March 1, 1958. On February 25, 1958, Medina filed a "CONSTANCIA" arguing certain pleadings need not be included. On March 1, 1958, Medina again failed to submit the amended record on appeal but was granted another five-day extension from receipt of the order dated March 1, 1958. Medina received this order on March 8, 1958. On March 12, 1958, Medina filed a "MOCION" to insert various documents, which was denied on March 29, 1958. The Petition: On April 1, 1958, after receiving notice of Parsons Hardware Co., Inc.'s motion for writ of execution (received March 28, 1958), Medina filed his amended record on appeal. The trial court, on April 12, 1958, disapproved the amended record on appeal as it was presented beyond the legal period and granted the writ of execution. The Court of Appeals granted Medina's petition for mandamus, suspending the execution and ordering the approval of the amended record on appeal. Parsons Hardware Co., Inc. filed this petition for review.
Issue(s)
Whether the Court of Appeals erred in granting the petition for mandamus and ordering the approval of the amended record on appeal despite its late filing. Whether the trial judge committed a manifest and gross abuse of discretion in disapproving the amended record on appeal.
Ruling
The petition is granted. The decision of the Court of Appeals is set aside, and the order of the Court of First Instance of Manila disapproving the amended record on appeal and issuing the writ of execution is affirmed.
Ratio Decidendi
On the issue of the Court of Appeals' grant of mandamus and approval of the amended record on appeal: The Supreme Court held that the appellant, Mariano Medina, failed to file his amended record on appeal within the time limited by the order of the trial court and the subsequent extensions granted. The rules require that if the trial judge orders an amendment, the appellant must redraft the record within the time limited or any extension thereof. Medina only filed his amended record on appeal after receiving notice of the appellee's motion for a writ of execution, which was beyond the reglementary period. The Court emphasized that mere "intention to obey" is not compliance with the rules; actual timely filing is required. On the issue of whether the trial judge committed a manifest and gross abuse of discretion: The Court reiterated the rule that if the record on appeal is filed outside the reglementary period, it is discretionary upon the trial judge to approve or disapprove it, and mandamus will lie only when there is a manifest and gross abuse of discretion. In this case, Medina repeatedly failed to submit the amended record on appeal on time, despite several extensions, without providing any valid reason for the delay. His filing only occurred after the motion for execution was filed. Under these circumstances, the trial judge acted correctly and did not commit any abuse of discretion in disapproving the amended record on appeal. The disapproval meant the appeal was never perfected, rendering the decision final and the issuance of the writ of execution in order. The Court cautioned that a liberal interpretation of the rules, as suggested by the Court of Appeals, should not open the door to dilatory tactics and should remain reasonable, especially when there is a repeated failure to comply with prescribed periods.
Main Doctrine
The failure to file an amended record on appeal within the reglementary period, despite extensions granted, renders the appeal unperfected, and the trial judge's disapproval of the belatedly filed record on appeal, when not attended by manifest and gross abuse of discretion, is proper, leading to the finality of the decision.