Republic v. Rodriguez
REITERATIONFacts
The Antecedents: The Republic of the Philippines filed a petition against Rosario T. Jalandoni to restrain her from taking possession of two cadastral lots occupied by the Iloilo Normal School since 1919. The Republic sought to have the lots appraised, pay their value at the time of government possession with interest, and cancel the original certificates of title in Jalandoni's name to issue new ones in the Republic's name. Procedural History: A preliminary injunction was issued to restrain Jalandoni from enforcing a writ of possession. Subsequently, the Court of First Instance (CFI) of Iloilo dismissed the Republic's petition for failure to state a cause of action and dissolved the injunction. Upon denial of its motion for reconsideration, the Republic filed a notice of appeal and a record on appeal. The Petition: The CFI denied the approval of the record on appeal, citing that the property had already been purchased by the plaintiff in a negotiated contract of sale, rendering the expropriation proceedings moot and academic. The Republic then filed a petition for a writ of mandamus to compel the CFI to approve its record on appeal and transmit it to the Supreme Court.
Issue(s)
Whether a writ of mandamus should issue to compel the Court of First Instance to approve the record on appeal filed by the petitioner and to transmit the same to the Supreme Court. Whether a trial court possesses the jurisdiction to dismiss an appeal on the ground that the case has become moot and academic, especially when the legality and implementation of a purported sale affecting the subject matter are still actively under inquiry or dispute.
Ruling
The Supreme Court granted the writ of mandamus, ordering the respondent court to approve and transmit the petitioner's record on appeal.
Ratio Decidendi
On Issue 1: The Supreme Court held that the writ of mandamus should issue. The Court reasoned that in refusing to allow the appeal to proceed on the ground that the case had become moot and academic, the trial court had, in fact, improperly proceeded to determine the merits of the petitioner's appeal. This action constituted an unauthorized trenching upon the exclusive jurisdiction vested in appellate courts. The Court noted that on 18 February 1966, the CFI was informed by counsel that the implementation of the sale of the lots to the Government had been suspended, and the legality of the sale was under inquiry. Furthermore, the validity of the deed of sale had been put in issue in another case before the Court of First Instance of Manila (Case No. 66225). Therefore, the trial court's pronouncement that the expropriation proceedings had become moot and academic was premature and constituted an abuse of discretion, justifying the issuance of the extraordinary writ. Mandamus is proper when a court neglects to perform an act specifically enjoined by law, or unlawfully excludes a party from a right. On Issue 2: The Supreme Court affirmed that a trial court's authority to dismiss an appeal is strictly delimited by the Rules of Court. Citing Sections 13 and 14 of Rule 41 of the Revised Rules of Court, the Court underscored that the only permissible grounds for dismissing an appeal in the trial court are the appellant's failure to timely file the notice of appeal, appeal bond, or record on appeal. The Court clarified that the provision in Section 9 of Revised Rule 41, which states an appeal is perfected upon approval of the record on appeal and bond, does not confer unbounded discretion upon the trial court to disapprove records on appeal for reasons other than non-compliance with Rule 41. To allow trial courts to dismiss appeals on substantive grounds like mootness would open the door for them to forestall review or reversal of their decisions by higher courts. The Court explicitly applied its prior ruling in Dosalla vs. Caluag, L-18765, where it held that grounds for appeal dismissal not enumerated in the Rules of Court can only be entertained by an appellate court, not by the court a quo, once an appeal has been procedurally perfected. The duty of the court a quo is, therefore, ministerial: to give due course to a procedurally perfected appeal.
Main Doctrine
A trial court cannot refuse to approve a record on appeal and transmit it to the appellate court on the ground that the case has become moot and academic, as this constitutes an unlawful exclusion of the petitioner from the right to prosecute an appeal and an encroachment upon the jurisdiction of the appellate courts. The grounds for dismissing an appeal are limited by the Rules of Court and do not include the trial court's determination of mootness.