G.R. No. 140858; November 27, 2001
Spouses Papa and Lolita Manalili, petitioners, vs. Spouses Arsenio and Gliceria De Leon, respondents.

FACTS

Petitioners, the spouses Manalili, mortgaged their property to a lending institution. Unable to redeem it, they sought the help of respondent spouses De Leon to secure a bank loan using the property as collateral. To facilitate the loan transfer, the parties executed a Deed of Sale over the property for a nominal amount, accompanied by a private Agreement stipulating that the sale would become null and void if petitioners complied with the loan terms, but would be binding if they defaulted. Petitioners defaulted on the bank installments, leading respondents to enforce the Agreement via an ejectment suit. Petitioners retaliated by filing a civil case, which the trial court dismissed.
Petitioners filed a Notice of Appeal. However, the Court of Appeals dismissed the appeal due to non-payment of the appellate docket fees within the reglementary period. Petitioners’ motion for reconsideration was denied, prompting this Petition for Review.

ISSUE

Whether the Court of Appeals erred in dismissing the appeal for non-payment of appellate docket fees and in refusing to relax the rule under the circumstances.

RULING

The Supreme Court denied the petition and affirmed the CA Resolutions. The Court emphasized that the right to appeal is a statutory privilege, not a constitutional right, and must be exercised in strict conformity with procedural rules. The payment of docket fees within the prescribed period for perfecting an appeal is mandatory and jurisdictional. Failure to comply results in the appellate court not acquiring jurisdiction over the subject matter, rendering the trial court’s decision final and executory.
Petitioners argued their non-payment was unintentional and due to inadvertence, as they were laypersons who failed to follow counsel’s instructions. The Court found this explanation insufficient to warrant an exception. While jurisprudence allows relaxation under exceptional circumstances to serve justice, mere inadvertence—especially a nearly ten-month delay after the reglementary period—does not constitute a compelling reason. Counsel’s responsibility to ensure compliance with appeal requirements cannot be excused by shifting blame to clients. Thus, the stringent rule was correctly applied.