GR 152530; (August, 2004) (Digest)
G.R. No. 152530 ; August 12, 2004
INSULAR LIFE SAVINGS AND TRUST COMPANY, petitioner, vs. SPOUSES FELIX MATEO RUNES, JR. and TRINIDAD RUNES, respondents.
FACTS
Respondents obtained a loan from petitioner’s predecessor, secured by a real estate mortgage. Upon default, the property was foreclosed and sold at auction to the bank. During the redemption period, the parties entered into a Contract to Sell over the same property. After respondents completed the installment payments under this new contract, petitioner refused to deliver the title, claiming an outstanding balance. Respondents thus filed an action for declaration of nullity of contract and sum of money. The Regional Trial Court (RTC) ruled in favor of respondents, declaring the Contract to Sell null and void as a prohibited pactum commissorium under Article 2088 of the Civil Code.
Petitioner received the RTC decision on August 8, 2000, and filed a motion for reconsideration on August 23, which was denied in an order received on October 26, 2000. Petitioner filed a Notice of Appeal on November 8, 2000. The RTC denied the appeal for being filed out of time and for failure to pay the appellate docket fees. Petitioner then filed a petition for relief from judgment with the RTC, which was denied. The Court of Appeals affirmed this denial, finding no grave abuse of discretion.
ISSUE
Whether the Court of Appeals erred in affirming the RTC’s denial of the petition for relief from judgment, thereby upholding the dismissal of petitioner’s appeal for being filed out of time.
RULING
The Supreme Court denied the petition, affirming the appellate court’s decision. The legal logic is anchored on the mandatory and jurisdictional nature of procedural rules on appeals. Perfection of an appeal within the reglementary period and payment of the required docket fees are strict requirements. The period to appeal is 15 days from notice of judgment or denial of a motion for reconsideration. Here, petitioner received the order denying its motion for reconsideration on October 26, 2000, making the last day to appeal October 27, 2000. The Notice of Appeal filed on November 8, 2000, was indisputably 12 days late. Furthermore, petitioner failed to pay the appellate docket fees within the prescribed period.
The Court emphasized that the right to appeal is a statutory privilege, not a natural right, and must be exercised in accordance with the law. Negligence of counsel binds the client. Granting relief for counsel’s oversight would lead to endless litigation, undermining the finality of judgments. The petitioner was not denied due process as it actively participated in the proceedings; it merely lost its right to appeal through its counsel’s failure to comply with procedural rules. Consequently, the RTC decision had become final and executory, and the petition for relief was correctly denied.