GR 120804; (June, 1996) (Digest)
G.R. No. 120804 June 14, 1996
FLORENTINO PEDROSA, petitioner, vs. SPOUSES EVELYN and REX HILL, and the COURT OF APPEALS, respondents.
FACTS
Petitioner Florentino Pedrosa filed a complaint for sum of money against respondent spouses Evelyn and Rex Hill. On April 8, 1994, the trial court rendered judgment ordering the spouses to pay Pedrosa. The spouses appealed to the Court of Appeals, which on December 8, 1994, required them to pay the docket fees within fifteen days from notice, warning that non-compliance would warrant dismissal. The spouses failed to pay within the prescribed period.
On April 7, 1995, counsel for the spouses filed a Motion for Admission of Payment of Docket Fee, citing inadvertence and forgetfulness. Pedrosa filed an Opposition and a Motion to Dismiss Appeal. On May 19, 1995, the appellate court denied Pedrosa’s motion and granted the spouses’ motion for admission. Pedrosa elevated the case via certiorari. Notably, the spouses also failed to file their required comment on the petition, with their counsel explaining he misplaced the Court’s resolution.
ISSUE
Whether the Court of Appeals committed grave abuse of discretion in admitting the belated payment of docket fees and not dismissing the appeal.
RULING
Yes. The Supreme Court granted the petition, set aside the appellate court’s resolution, and declared the trial court’s decision final and executory. The legal logic is anchored on the jurisdictional nature of perfecting an appeal. Payment of the full docket fee within the reglementary period is mandatory and jurisdictional. An appeal is a statutory privilege, not a natural right, and its requirements must be strictly complied with. Failure to pay on time renders the lower court’s decision final and executory and deprives the appellate court of jurisdiction to entertain the appeal.
The Court rejected the spouses’ excuses of inadvertence and counsel’s oversight as unsatisfactory. It emphasized that procedural rules, especially those governing the perfection of appeals, are not mere technicalities but essential steps to vest jurisdiction. While relaxation is allowed under exceptional circumstances, no such compelling reason existed here, given the four-month delay and the parties’ continued disregard of procedural directives, including the failure to comment on the petition. The Court of Appeals thus gravely abused its discretion in excusing the delay.