G.R. No. 131686 March 18, 2002
ROUEL AD. REYES, petitioner, vs. SPOUSES PEPITO and MARTA TORRES, HON. ELIEZER R. DELOS SANTOS, Executive Judge, RTC, Angeles City, respondents.

FACTS

Petitioner Rouel AD. Reyes purchased a parcel of land in Mabalacat, Pampanga in 1993, which was occupied by tenants including respondent spouses Pepito and Marta Torres. After written demands to vacate and failed barangay conciliation, petitioner filed an ejectment case before the Municipal Circuit Trial Court (MCTC). The MCTC ruled in favor of petitioner, ordering respondents to vacate, remove structures, pay rentals, and pay attorney’s fees. Respondents appealed to the Regional Trial Court (RTC) and filed a supersedeas bond. The RTC initially dismissed the appeal for failure to pay docket fees. Respondents filed a motion for reconsideration, attaching receipts to prove payment made to the MCTC Clerk of Court, which the latter failed to transmit. The day before the hearing on their motion, respondents also filed a petition for certiorari and prohibition with another RTC branch (docketed as Civil Case No. 8794) assailing a writ of execution issued by the MCTC, which was nonetheless enforced, demolishing respondents’ structures. Respondents failed to appear at the hearing for their first motion for reconsideration, which was denied. They then filed a second motion for reconsideration, explaining their counsel’s late arrival due to awaiting a TRO in their other case and heavy traffic. The RTC issued an Order reinstating the appeal upon finding proof of payment of docket fees. Petitioner filed a motion for reconsideration, which was pending when the case was raffled to another RTC branch, which then directed the submission of memoranda. Petitioner then filed the instant petition for certiorari.

ISSUE

Whether the Regional Trial Court committed grave abuse of discretion in reinstating the appeal of the respondents despite procedural lapses, including the filing of a second motion for reconsideration.

RULING

No, the Regional Trial Court did not commit grave abuse of discretion. The Supreme Court dismissed the petition. Procedural rules, while important, should not be applied rigidly to override substantial justice. The dismissal of the appeal for non-payment of docket fees was erroneous, as respondents had paid the fees to the MCTC Clerk of Court within the prescribed period, and the failure to transmit the proof of payment was not respondents’ fault but the clerk’s omission under Rule 40, Section 5 of the Rules of Court. The matters in the first and second motions for reconsideration were not identical, as they addressed different orders. A strict prohibition on a second motion in this instance would be unreasonable, as both dismissal orders were based on technicalities, not the merits. Denying the appeal would deprive respondents of their statutory right to appeal, especially since the procedural lapses were not intended to delay nor prejudiced petitioner. Courts have equity jurisdiction to stay the dismissal of an appeal on mere technicalities when the non-compliance is not dilatory and no prejudice is caused. Litigations should be decided on the merits. The case was remanded to the RTC for proceedings on the merits.