Pfleider v. Victoriano
REITERATIONFacts
1. The Antecedents: The underlying dispute involves the spouses William C. Pfleider and Madalena S. Pfleider against spouses Potenciano A. Palanca and Hermelina Pulmones, stemming from Civil Case No. 9187 in the Court of First Instance of Negros Occidental. The specifics of the original dispute are not detailed in this excerpt, but the case reached the Supreme Court due to issues with the appellate process. 2. Procedural History: The spouses Pfleiders appealed an amended decision from the Court of First Instance (CFI) of Negros Occidental to the Court of Appeals (CA). While perfecting their appeal, they filed a special civil action (CA G.R. No. Sp-07561) questioning a CFI order to amend their record on appeal. Subsequently, the CA, Ninth Division, dismissed their main appeal (CA G.R. No. 63411-R) for failing to submit the required printed copies of the record on appeal within the reglementary period. A motion for reconsideration was denied. The Pfleiders then filed a petition for review on certiorari with the Supreme Court, which was initially granted an extension but later withdrawn upon receiving a CA resolution that granted their motion for reconsideration and suspended the period for submitting the record on appeal. However, the CA's Ninth Division later set aside this resolution, and a subsequent motion for reconsideration was denied. The Pfleiders then moved to revive their petition for review on certiorari with the Supreme Court, which was granted, along with a temporary restraining order. 3. The Petition: The Supreme Court is reviewing a petition for certiorari filed under Rule 45 of the Rules of Court. The petition seeks to overturn the Court of Appeals' resolution dated October 18, 1978, which dismissed the appellants' appeal. The Supreme Court ultimately found the petition for review on certiorari to be filed out of time, as the fifteen-day period to appeal from the October 18, 1978 resolution (or the denial of a motion for reconsideration) had expired. The Court also noted that even if timely, the petition lacked merit due to the appellants' failure to comply with the CA's rules regarding the submission of the printed record on appeal.
Issue(s)
Whether the petition for review on certiorari was filed within the reglementary period. Whether the Court of Appeals acted within its powers in dismissing the appeal for failure to submit the printed record on appeal within the prescribed period. Whether the pendency of a separate certiorari case justified the petitioners' failure to comply with the CA's order to submit the printed record on appeal.
Ruling
The Supreme Court denied the Petition for Review on Certiorari, lifted the temporary restraining order, and ordered the Clerk of Court of the Court of Appeals to revise CA-Judicial Form No. 1 to conform to the Rules of Court regarding the number of copies of the record on appeal. The Docket Division of the Supreme Court was also directed to be guided by the resolution.
Ratio Decidendi
On Issue 1: The Supreme Court held that the petition for review on certiorari was filed out of time. Petitioners admitted receiving the Court of Appeals' resolution dated October 18, 1978, on October 25, 1978. Under Section 1, Rule 45 of the Rules of Court, they had fifteen (15) days from notice to file either a motion for reconsideration with the CA or a petition for review on certiorari with the Supreme Court. This period expired on November 9, 1978. Consequently, their motion for reconsideration filed on November 23, 1978, their motion for extension filed on January 24, 1979, and their petition for review filed on February 22, 1979, were all filed beyond the reglementary period. The earlier grant of an extension of time was conditioned upon the timeliness of the motion, which was not met. On Issue 2: The Supreme Court affirmed that the Court of Appeals acted within its powers in dismissing the appeal. Section 5, Rule 46 of the Rules of Court, as amended, mandates appellants to submit printed or typewritten copies of the record on appeal within sixty (60) days from notice. The failure to comply with this duty grants the Court of Appeals the implicit power to dismiss the appeal. In this case, the petitioners failed to submit the required copies despite notice, making the dismissal by the CA on October 18, 1978, a valid exercise of its authority. On Issue 3: The Supreme Court ruled that the pendency of CA G.R. No. SP-07561 did not justify the petitioners' refusal to comply with the CA's order to submit the printed record on appeal. The Court found it contradictory for the petitioners to question the trial court's order for amendment while simultaneously complying with it and then refusing to submit the amended record on appeal to the CA. To allow such a stance would permit parties to assume contradictory positions before the court, which is impermissible. The CA was not obligated to suspend the period for submitting the record on appeal simply because of the pending certiorari case.
Main Doctrine
The Supreme Court reiterated that a petition for review on certiorari must be filed within the reglementary period of fifteen (15) days from notice of the judgment or denial of a motion for reconsideration. The Court emphasized that after the lapse of this period, the judgment becomes final, and the appellate court loses jurisdiction. Consequently, any subsequent motion for reconsideration or petition for review filed out of time cannot revive the lost jurisdiction or disturb the finality of the judgment. The Court also affirmed the appellate court's inherent power to dismiss an appeal for non-compliance with procedural rules, such as the failure to submit the required copies of the record on appeal within the prescribed period.