Lee v. Land Bank
REITERATIONFacts
1. The Antecedents: Spouses Edmond Lee and Helen Huang (petitioners) are the registered owners of a parcel of land in Bataan. The Department of Agrarian Reform (DAR) compulsorily acquired a portion of this land under Republic Act No. 6657. The DAR offered P109,429.98 as just compensation for a 1.5073-hectare portion, which the petitioners rejected. Consequently, the petitioners filed a petition for the determination of just compensation against the DAR Adjudication Board and the Land Bank of the Philippines before the Regional Trial Court (RTC), acting as a Special Agrarian Court (SAC). 2. Procedural History: The RTC, in Civil Case No. 7171, initially ruled on January 17, 2002, setting the just compensation at P250.00 per square meter, totaling P3,768,250.00. The respondent Land Bank of the Philippines filed a Notice of Appeal. After several years, the petitioners filed a motion to dismiss the appeal for failure to prosecute, asserting that the appeal fees were not paid and the records were not transmitted to the Court of Appeals (CA). The RTC, in an Order dated July 5, 2013, granted the motion and dismissed the appeal, finding that the appeal fees were not remitted. The respondent's motion for reconsideration was denied. The respondent then elevated the matter to the CA via a petition for certiorari, arguing grave abuse of discretion by the RTC. 3. The Petition: The Court of Appeals, in a Decision dated January 28, 2015, reversed the RTC's dismissal, finding grave abuse of discretion and holding that the RTC had lost jurisdiction after giving due course to the appeal. The petitioners, aggrieved by the CA's ruling, filed the present petition for review on certiorari under Rule 45 of the Rules of Court. They argue that the CA erred in finding grave abuse of discretion, contending that the RTC correctly dismissed the appeal for failure to perfect it by not paying the appellate docket fees, which is a mandatory and jurisdictional requirement. The Supreme Court is asked to determine whether the CA correctly found the RTC to have committed grave abuse of discretion.
Issue(s)
Whether the Court of Appeals erred in finding grave abuse of discretion on the part of the Regional Trial Court when it dismissed respondent's appeal for failure to prosecute. Whether respondent Land Bank of the Philippines perfected its appeal before the Regional Trial Court.
Ruling
The petition is GRANTED. The Decision dated January 28, 2015 and the Resolution dated June 5, 2015 of the Court of Appeals in CA-G.R. SP No. 133533 are REVERSED and SET ASIDE. Accordingly, the Orders dated July 5, 2013 and December 11, 2013 of the Regional Trial Court of Balanga City, Bataan, Branch 1, sitting as a Special Agrarian Court, are AFFIRMED.
Ratio Decidendi
On the issue of whether the Court of Appeals erred in finding grave abuse of discretion on the part of the Regional Trial Court when it dismissed respondent's appeal for failure to prosecute: The Supreme Court ruled that the CA erred in finding grave abuse of discretion on the part of the RTC. The Court emphasized that the payment of appellate docket and other lawful fees within the prescribed period is mandatory and jurisdictional, as provided under Section 4, Rule 41 of the Rules of Court. Failure to pay these fees means the appeal is not perfected, and the appellate court does not acquire jurisdiction over the case. Consequently, the decision sought to be appealed becomes final and executory. In this case, the RTC, through its OIC Clerk of Court, found that while Land Bank issued a postal money order for the appeal fee, the amount was never remitted or received by the court. Without proof of payment of the required appellate fees, the records could not be transmitted to the CA, and the case remained with the RTC. Therefore, the RTC did not lose jurisdiction over the case and could properly dismiss the appeal for failure to prosecute. The Court noted that Land Bank failed to provide proof of payment, despite the lapse of almost five years from the time its appeal was initially given due course. This inaction and failure to comply with mandatory procedural requirements led to the dismissal of its appeal. On the issue of whether respondent Land Bank of the Philippines perfected its appeal before the Regional Trial Court: The Supreme Court held that Land Bank failed to perfect its appeal before the RTC. The perfection of an appeal is a jurisdictional requirement that necessitates compliance with the rules, including the payment of full appellate docket fees within the reglementary period. Section 4 of Rule 41 explicitly states that the appellant shall pay the full amount of the appellate court docket and other lawful fees within the period for taking an appeal. The Court reiterated the ruling in Gipa v. Southern Luzon Institute and Gonzales v. Pe, clarifying that the payment of docket fees is not merely directory but mandatory and jurisdictional. Without such payment, the appeal is not perfected, and the appellate court acquires no jurisdiction. The RTC's earlier orders giving due course to the appeal were based on the representation that the fees were paid, but a subsequent meticulous inspection of the records revealed non-remittance. Section 9 of Rule 41 also provides that in appeals by notice of appeal, the court loses jurisdiction over the case upon the perfection of appeals filed in due time and the expiration of the time to appeal of the other parties. Since Land Bank failed to perfect its appeal by not paying the required fees, the RTC retained jurisdiction and was empowered to dismiss the appeal for failure to prosecute. The Court concluded that the dismissal of Land Bank's appeal was in order, and the RTC's January 17, 2002 Decision had attained finality.
Main Doctrine
The payment of appellate docket fees within the prescribed period is mandatory and jurisdictional. Failure to pay these fees means the appeal is not perfected, and the appellate court does not acquire jurisdiction, rendering the decision final and executory. The RTC retains jurisdiction to dismiss the appeal for failure to prosecute if the appeal was not perfected.