GR 109721; (March, 1999) (Digest)
G.R. No. 109721 March 11, 1999
Felix A. Sajot, petitioner, vs. Court of Appeals and People of the Philippines, respondents.
FACTS
Petitioner Felix A. Sajot was convicted of estafa by the Regional Trial Court. He filed a notice of appeal. The Court of Appeals required him to file his appellant’s brief. The court granted three extensions of time for filing. Despite these extensions, petitioner failed to file the brief. Consequently, the Court of Appeals dismissed his appeal for such failure.
Petitioner, acting on his own, filed an Urgent Motion for Reconsideration, which was denied. He then engaged new counsel and filed another Motion for Reconsideration. This second motion was denied by the appellate court for being a prohibited pleading. Petitioner thus filed this petition for certiorari, arguing that the dismissal of his appeal constituted a denial of due process, primarily attributing the failure to file the brief to his former counsel’s gross negligence.
ISSUE
Whether the Court of Appeals committed grave abuse of discretion in dismissing petitioner’s appeal for failure to file the required appellant’s brief.
RULING
The Supreme Court ruled that the Court of Appeals did not commit grave abuse of discretion. An appeal is a statutory privilege that must be exercised in strict conformity with procedural rules. Rule 50, Section 1(e) of the Revised Rules of Court explicitly authorizes the dismissal of an appeal for the appellant’s failure to file the required brief within the granted period.
The Court rejected the petitioner’s claim of denial of due process due to counsel’s negligence. The legal logic is grounded in the principle that a client is generally bound by the actions, or inaction, of his counsel. More critically, the Court found petitioner himself guilty of neglect. He was aware of the conviction and the briefing requirement. His excuse of reliance on counsel and being busy was deemed flimsy and indicative of a lack of vigilance, a trait also observed by the trial court during the proceedings. The Court emphasized that procedural rules are designed to ensure orderly administration of justice, and their relaxation is not a right for erring litigants. Since petitioner did not strictly comply with the rules and showed his own negligence, the dismissal of the appeal was proper. No grave abuse of discretion attended the appellate court’s resolutions.