G.R. No. 128628 ; August 23, 2001
ILDEFONSO SAMALA AND BENJAMIN BABISTA, petitioners, vs. THE HON. COURT OF APPEALS, THE HON. REGIONAL TRIAL COURT, Branch 15, Naic, Cavite, and ROMULO OCAMPO, respondents.

FACTS

On October 19, 1990, a Super Saint Bus owned by Ildefonso Samala and driven by Benjamin Babista sideswiped a motorcycle, injuring Romulo Ocampo, a passenger. The bus fled the scene. Ocampo filed a complaint for damages. On May 15, 1995, the Regional Trial Court (RTC) rendered a decision in favor of Ocampo, ordering petitioners to pay various damages jointly and severally. Petitioners received a copy of the decision on September 29, 1995. They filed a notice of appeal on October 16, 1995. The RTC denied the appeal on October 17, 1995, ruling it was filed beyond the 15-day reglementary period. Petitioners filed a petition for relief, arguing that the person entrusted to file the notice, Jose Samala, Jr., suffered from diarrhea on October 11-12, 1995, preventing timely filing; he filed it on the next business day, October 16, believing the period had not lapsed. The RTC denied the petition for relief on February 21, 1996. The RTC also granted Ocampo’s motion for a writ of execution on March 20, 1996. Petitioners filed a petition for certiorari and prohibition with the Court of Appeals (CA), assailing the denial of the petition for relief. The CA denied the petition on September 17, 1996, and denied reconsideration on March 7, 1997.

ISSUE

Whether the Court of Appeals erred in refusing to grant petitioners’ relief from the order denying their appeal, specifically, whether the one-day delay in filing the notice of appeal constituted excusable negligence.

RULING

The Supreme Court GRANTED the petition, REVERSED the decision of the Court of Appeals, and ordered the RTC to elevate the records to the CA for review. The Court held that the one-day delay in filing the notice of appeal constituted excusable negligence. The last day to file was Friday, October 13, 1995. The entrusted person, Jose Samala, Jr., suffered from stomach pains (diarrhea) from October 11, preventing him from filing. He filed it on the next business day, Monday, October 16, in good faith. The delay was thus for only one day (excluding Saturday and Sunday). The Court emphasized that procedural rules are tools to facilitate justice, not hinder it. Technicalities that frustrate substantial justice must be avoided. Where no intent to delay justice is present, a one-day delay does not justify denying an appeal. The Court cited precedent (United Airlines v. Uy) where a two-day delay was excused due to the case’s peculiar facts. The primordial end is to dispose of cases on their merits. The dissenting opinion of Chief Justice Davide, Jr., joined by Justice Puno, argued that the decision unduly relaxed the rule on appeal periods and established a problematic precedent.