Crisologo v. Court of Appeals
REITERATIONFacts
1. The Antecedents: The petitioners, claiming to be legal heirs of Lutgarda Capiao, filed an action against the private respondent for ownership, annulment of sale, and delivery of possession of various properties. They sought to annul four deeds of sale covering seventeen parcels of land and a residential house, alleging that Lutgarda Capiao, their relative, had executed these deeds in favor of the private respondent. The core of the dispute hinged on whether the petitioners, as legitimate relatives of Lutgarda's mother, Julia Capiao, could inherit from Lutgarda, who was an illegitimate child, in light of Article 992 of the Civil Code which prohibits inheritance between legitimate relatives of the parent and an illegitimate child. 2. Procedural History: After the trial court denied the private respondent's motion to dismiss, a summary judgment was rendered dismissing the petitioners' amended complaint. The petitioners received this decision on April 22, 1974, and after a motion for reconsideration was denied, they filed a notice of appeal on August 26, 1974, intending to appeal directly to the Supreme Court. Their record on appeal was initially approved on October 2, 1974, but this approval was revoked the same day. Subsequently, on January 24, 1975, the trial court dismissed the record on appeal for being filed out of time. The petitioners then filed a special civil action for mandamus with the Court of Appeals, seeking to compel the trial judge to approve their record on appeal. The Court of Appeals dismissed this petition for lack of appellate jurisdiction. 3. The Petition: The petitioners seek review of the Court of Appeals' decision dismissing their special civil action for mandamus. They raise two main legal questions: first, whether the trial court committed grave abuse of discretion in dismissing their appeal for being filed out of time, and second, whether the Court of Appeals acted in accordance with law and Supreme Court rulings when it dismissed their petition for mandamus. The petitioners argue that the trial court erred in dismissing their appeal and that the Court of Appeals should have either entertained the mandamus petition or elevated it to the Supreme Court. The petition before this Court is a petition for review on certiorari under Rule 45 of the Rules of Court.
Issue(s)
Whether the trial court committed grave abuse of discretion in dismissing the petitioners' appeal on the ground that the record on appeal was filed out of time. Whether the Court of Appeals acted in accordance with law and applicable Supreme Court decisions in dismissing the petition for mandamus, and whether it departed from the usual course of judicial proceedings.
Ruling
The petition is dismissed for lack of merit. The Court holds that the trial court acted correctly in dismissing the appeal, and the Court of Appeals correctly dismissed the petition for mandamus.
Ratio Decidendi
On the first issue (Grave Abuse of Discretion in Dismissing Appeal): The Supreme Court affirmed the trial court's dismissal of the appeal. The records showed that the petitioners filed their record on appeal nineteen days after the last day to perfect the appeal. Furthermore, the record on appeal did not include the Motion for Summary Judgment with its annexes and exhibits, nor was there a motion for an extension of time to file it. The appeal bond was also filed fifteen days late. The Court reiterated the well-rooted principle that the perfection of an appeal within the statutory or reglementary period is not only mandatory but also jurisdictional. Failure to comply with this requirement renders the questioned decision final and executory, depriving the appellate court of jurisdiction to alter the judgment or entertain the appeal. In this case, the petitioners' notice of appeal was filed on June 4, 1976, long after the reglementary period, which ended on May 9, 1976, making the decision final and executory. The Court found no reason to exercise liberality in allowing the late filing, as the lower court's decision was satisfactorily supported by the records, particularly the application of Article 992 of the Civil Code. On the second issue (Court of Appeals' Dismissal of Mandamus Petition): The Supreme Court held that the appellate court correctly dismissed the petition for mandamus. The petitioners had stated their intention to appeal the main case directly to the Supreme Court. Consequently, the Court of Appeals could not exercise appellate jurisdiction over the petition for mandamus, as it was merely incidental to the main case. The Court cited Philippine National Bank v. Court of Appeals and Philippine Products Co. v. Court of Appeals, which established that the Court of Appeals may only issue writs like mandamus, certiorari, and prohibition in aid of its appellate jurisdiction. This means the Court of Appeals can only act on such special civil actions if the main case falls under its exclusive appellate jurisdiction. Since the main case was intended to be appealed directly to the Supreme Court, jurisdiction to act on the incidental mandamus petition devolved upon the Supreme Court. Moreover, the Court reiterated that a writ of mandamus cannot be used to control the discretion of a judge or compel them to decide a case in a particular way; it is available only to compel the exercise of discretion or jurisdiction. The respondent judge could not be compelled to approve an appeal perfected out of time. The Court also noted that since the main case was manifestly without merit, there were no considerations of substantial justice warranting the exercise of equity powers or certification of the petition to the Supreme Court.
Main Doctrine
The perfection of an appeal within the reglementary period is mandatory and jurisdictional; failure to do so renders the decision final and executory. A petition for mandamus cannot compel a judge to approve a record on appeal filed out of time, nor can the Court of Appeals exercise appellate jurisdiction over a special civil action that is merely incidental to a main case appealed directly to the Supreme Court.