G.R. No. L-2124
FACTS:
Plaintiff-appellant Simeon Du-Yungco filed an action for damages against defendant-appellee Macario Barrera, a customs inspector, in the justice court of Langaran, Misamis. The justice court ruled in favor of Du-Yungco. Barrera attempted to appeal the decision by filing a notice of appeal to the Court of Customs Appeals, pursuant to Act No. 355, and posted the required bond. Du-Yungco moved to remand the case to the justice court, arguing the appeal was improperly taken. The Court of First Instance (CFI) of Misamis denied the motion, holding that while the appeal was mistakenly directed to the Court of Customs Appeals, the error did not vitiate the appeal and the CFI could properly assume jurisdiction. Du-Yungco then filed a complaint in the CFI, which was a reproduction of his original complaint. After trial, the CFI rendered a judgment. Du-Yungco appealed, contending the CFI never acquired jurisdiction because the appeal from the justice court was fatally defective.
ISSUE:
Whether the defendant’s appeal from the judgment of the justice court to the Court of Customs Appeals, instead of to the Court of First Instance as required by law, was valid so as to confer jurisdiction on the Court of First Instance over the case.
RULING:
Yes, the appeal was valid, and the Court of First Instance properly acquired jurisdiction. The Supreme Court affirmed the orders and judgment of the CFI.
The law governing appeals from justice courts (Section 74 of the Code of Civil Procedure) provides that appeals lie to the Court of First Instance of the province. No statute, including Act No. 355, authorizes an appeal from a justice court to the Court of Customs Appeals. However, the defendant’s clear intention was to appeal from the adverse judgment, and he perfected his appeal within the prescribed period. The mere error in designating the appellate court does not nullify the appeal. When a party appeals without specifying the court, or mistakenly names an incorrect court, the appeal is understood by law to be made to the Court of First Instance, as it is the only court statutorily designated to hear such appeals. The plaintiff’s subsequent act of filing and prosecuting a complaint in the CFI, which was identical to his original complaint, further validated the proceedings. Therefore, the CFI’s assumption of jurisdiction was correct.