G.R. No. 135638; January 20, 2003
OSCAR A. BAGO, petitioner, vs. PEOPLE OF THE PHILIPPINES, respondent.

FACTS

Petitioner Oscar A. Bago was convicted of Falsification of Public Document by the Regional Trial Court of Manila. He appealed to the Court of Appeals, which directed him to file his Appellant’s Brief by December 22, 1997. According to the report of the Judicial Records Division of the Court of Appeals, no appellant’s brief was filed within the given period. The appellate court required petitioner to show cause why his appeal should not be considered abandoned. Petitioner’s counsel filed a manifestation explaining that the brief was filed seasonably by his secretary but the original was inadvertently filed with the copies for the Brief Section due to ongoing Christmas parties, and that the Office of the Solicitor General was furnished a copy late due to the secretary’s failure. The Court of Appeals was not satisfied with this explanation and dismissed the appeal. Petitioner’s motion for reconsideration was denied.

ISSUE

Whether the Court of Appeals erred in dismissing petitioner’s appeal for his failure to file the Appellant’s Brief within the reglementary period.

RULING

The Supreme Court DENIED the petition and AFFIRMED the Resolution of the Court of Appeals. The Court held that rules prescribing time within which acts must be done are indispensable to prevent needless delays and ensure orderly and speedy discharge of judicial business. Strict compliance with such procedural rules is mandatory and imperative. While the Court may allow exceptions based on strong considerations of equity in the interest of substantial justice, petitioner failed to show compelling reasons to relax the rules in his favor. His failure to comply strictly with the procedural requirements and reglementary periods does not warrant the application of equity or liberal construction of the Rules.