Pimentel v. Court of Appeals
REITERATIONFacts
The Antecedents: Petitioners-spouses Juan C. Pimentel and Salud de los Reyes filed an application for the registration of a residential lot on October 2, 1969. This application was opposed by private respondents Paulino O. Oriel and Macaria Ruiz, who had previously filed their own application for the same lot on September 24, 1968. The Court of First Instance of Pangasinan conducted a joint trial for both applications. Procedural History: On September 20, 1973, the trial court rendered a decision in favor of the private respondents. Petitioners received this decision on September 25, 1973, and subsequently filed their notice of appeal on October 13, 1973. They deposited an appeal bond and filed a motion for an extension to file their record on appeal, which was granted for 30 days from October 25, 1973. After facing objections regarding typographical errors and omissions, corrected records on appeal were filed on January 4, 1974, and finally approved by the trial court on January 24, 1974, which noted that the appeal was perfected within the reglementary period. The Petition: The petitioners seek to annul the resolutions of the Court of Appeals dated July 15, 1974, and September 11, 1974, which dismissed their appeal. The dismissal was based on the argument that the records on appeal failed to include material data showing the appeal was seasonably perfected. The petitioners contend that the trial court's order of January 24, 1974, approving the records on appeal, implicitly confirmed that the appeal was perfected on time, and this fact was not disputed by the private respondents. They argue that the appellate court should have relied on this order, rendering the dismissal an abuse of discretion.
Issue(s)
Whether the Court of Appeals committed a grave abuse of discretion in dismissing the appeal. Whether the approval of the records on appeal by the trial court, despite the omission of certain documents related to the extension of time, was sufficient to establish the timeliness of the appeal.
Ruling
The Supreme Court set aside the resolutions of the Court of Appeals dated July 15, 1974, and September 11, 1974, as null and void, and directed the Court of Appeals to give due course to the appeal.
Ratio Decidendi
On the issue of whether the Court of Appeals committed a grave abuse of discretion in dismissing the appeal: The Court held that the respondent Court of Appeals acted with grave abuse of discretion in dismissing the appeal. This dismissal was based on the alleged failure of the records on appeal to include material data showing that the appeal was seasonably perfected. However, the private respondents did not question the correctness of the trial court's order dated January 24, 1974, which approved the records on appeal. This order explicitly stated that there were no more objections and that the notice of appeal, records on appeal, and appeal bonds were filed within the reglementary period. The Supreme Court found that the private respondents' failure to impugn the factual assertions in the trial court's approval order meant they implicitly admitted those facts. Therefore, the appellate court should have relied on the trial court's order of approval, which contained the necessary data to establish the timeliness of the appeal. On the issue of whether the approval of the records on appeal by the trial court was sufficient: The Court reasoned that the purpose of Section 6, Rule 41 of the Revised Rules of Court, which requires the record on appeal to include data showing timely perfection, is to prevent the appellate tribunal from wasting time. In this case, the trial court's order of January 24, 1974, explicitly approved the records on appeal because it found that the notice of appeal, records on appeal, and appeal bonds were filed within the reglementary period, and there were no further objections. The veracity of the grounds stated in this order was not disputed by the private respondents. Consequently, the appellate court could have relied on this order to determine that the appeal was perfected on time, obviating the need to send for the original records or conduct further examination. The Court cited its ruling in Berkenkotter vs. Court of Appeals and Isidro Climaco (L-36629, Sept. 29, 1973), where it held that the mere absence of a formal order granting a motion for extension of time to file a record on appeal is not fatal if the record on appeal filed within the requested extension period was approved by the trial court. The approval of the record on appeal carries with it the approval of the motion for extension, and the failure of the record to explicitly show this approval should not defeat the right to appeal, as a trial judge would not approve a record on appeal that was not timely filed.
Main Doctrine
The approval of a record on appeal by the trial court, which contains factual statements indicating that the appeal was perfected within the reglementary period, can be relied upon by the appellate court, even if the record on appeal does not explicitly include all supporting documents for the extension of time, as the approval itself implies the acceptance of the timeliness of the appeal.